Welcome to the spring 2025 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for tax and legal in-house professionals.
As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.
In this edition, we look at just a few of these developments, including the latest in relation to BEPS Pillar Two and potential disputes, plus the latest series of HMRC nudge campaigns.
We also cover a number of notable tax cases and other interesting procedural decisions. This includes the most recent case law development on deductibility of payments, allocation of taxing rights under a double tax treaty and an interim decision on partial closure notices.
