elcome to the Summer 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other 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 HMRC’s position on the salaried member rules and 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 the unallowable purpose test within the loan relationship rules and some landmark decisions in relation to VAT and management expenses.
