UK Tax Disputes Digest (Winter 2024)

United Kingdom
12/12/2024
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Welcome to the Winter 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 in relation to 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 developments on the unallowable purpose test within the loan relationship rules, the meaning of fixed establishment for the purposes of VAT grouping and a recap of the Budget and other recent developments.

Click here to read the report.

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