Tag: Tax Disputes

Post Office Scandal Mr Bates LEXLAW Tax Disputes HMRC Solicitors Appeal

British Post Office Horizon IT Scandal: HMRC’s ancillary attack on UK Postmasters

HMRC have been using Horizon Data to raise tax assessments and tax penalties against innocent sub-postmasters. In one such case only after a six year battle when HMRC faced paying costs did they decide to withdraw their tax demands. Even now they refuse to recognise their misconduct should be punished by them paying indemnity costs and have threatened the sub-postmaster victim with a costs order simply for daring to ask for his full costs.

HMRC Building

Defending a HMRC Security Notice of Requirement

A HMRC Security Notice is a formal notice issued by HM Revenue and Customs (HMRC) to an individual or business requiring them to provide security for certain future tax liabilities. It is a tool used by HMRC where they believe there is a risk of tax loss.

Challenging Validity of Discovery Assessments; Robert Don Hunter Dougan v HMRC

In the case of Robert Don Hunter Dougan v HMRC [2022] TC8471, the First Tier Tribunal (“FTT”) ruled the taxpayer had not deliberately intended to cause a loss…

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High Court: Accountant’s report can be disclosed in litigation

For privilege to apply, there must be a lawyer (i.e. a solicitor or barrister) in the communication for legal advice privilege to apply. Legal advice privilege does NOT extend to other professionals such as accountants. Therefore, in disputes with HMRC for example, (potentially incriminating) communications with an accountant can be disclosed and are not privileged.

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Court of Appeal Decision: Mobilx, Blue Sphere, Calltel

Court of Appeal in conjoined appeal cases of Mobilx, Blue Sphere Global and Calltel upholds previous lower court decisions and provides new guidance on the ‘Kittel’ test. The approved judgement is…

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Brayfal Decision Highlights the Importance of the a Three Person VAT Tribunal

The case report [download] from the Manchester former VAT and Duties Tribunal contains useful information relevant to the means of knowledge appeal cases we regularly conduct. The tribunal…