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19 April 20221 minute read

Contentious Tax Quarterly Briefing

In a continuation of a recent trend for cases to be broken down and heard in parts, two significant decisions on preliminary issues have been released since the turn of the year. The First-tier Tribunal has also provided a united position that just because a payment at the end of a regulatory investigation isn’t described as a penalty, does not mean it won’t be treated as such for deductibility purposes if it is, at its heart, penal in nature. Following our Freedom of Information Act request, HMRC has now started to publish tax under consideration figures broken down by sector; and HMRC’s large business review shows that more could be done to provide greater certainty to taxpayers, including through better guidance being published.