Tax Disputes Digest - Spring 2026 Edition
Welcome to the spring 2026 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 in relation to a key capital allowances decision on pre-construction surveys and studies.
We also analyse key data-driven findings and analysis in a new CMS report, ‘Tax under scrutiny: HMRC disputes and pressure points’, which collates and analyses HMRC’s investigation and litigation activity since 2018.
