CMS UK Tax Disputes Digest (March 2023)

England and Wales
24/03/2023
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Welcome to the March 2023 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.

In our last edition (November 2022), we noted that pressure on the Government to recover money through closing the tax gap and related announcements would inevitably see HMRC ramping up activity.  Since then, we have noticed a marked increase in HMRC investigations 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.  Please also see the “Other developments” section for new announcements made in the Spring 2023 Budget on how the Government intends to tackle the tax gap.

In this edition, we look at just a few of the latest developments, including an update on HMRC’s use of financial institution notices (where our team has helped to secure an important victory for financial institutions and taxpayer privacy), corporate criminal offences, transfer pricing and diverted profits tax investigations, and the latest series of HMRC nudge campaigns (including a new campaign on R&D tax relief).

We also cover a number of notable tax cases and other interesting procedural decisions, including a recent win for a high-profile taxpayer on IR35.

In addition, we are conscious that the media has been awash with stories about the terms of a settlement between HMRC and a certain former Chancellor regarding his personal tax affairs, and in particular that the tax errors in question had been treated as “careless” rather than “deliberate”.  While we make no comment on the individual settlement in question, this edition provides a helpful summary of what those terms mean in the context of penalties for tax errors.

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