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Appeals, disputes and investigations

Expert commentary and practical guidance from ICAEW related to appeals, disputes and investigations relating to compliance with UK tax regime.

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Mandatory disclosure rules and DAC 6

Practical guidance and support on tax disclosure around the world, including the UK's Mandatory Disclosure Rules and DAC 6.
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Professional conduct in relation to taxation (PCRT)

PCRT sets out the principles and standards of behaviour that all members, affiliates and students must follow in their tax work.
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Exclusive

Tax Round-up 2020

This webinar from the Tax Faculty provides a round up of all the measures that are under review and subject to consultation, and how the faculty will be responding.
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Practical guidance

ICAEW's Tax Faculty produces TAXguides to provide practical support on technical areas of tax.

TAXguide 18/17: HMRC determinations and special relief
  • Technical release
  • 03 Nov 2017
In TAXguide 18/17, Caroline Miskin explains what special relief is, when it might apply and the conditions that need to be met to make a formal claim. Read a summary here, Tax Faculty members can download the full guide.
TAXguide 12/17: CRS - notifying clients
  • Technical release
  • 30 Jun 2017
An explanation of the legal requirement for financial institutions and professionals to write to clients to whom they have given advice on offshore matters. The guide outlines the rules, suggests how you might comply and provides a draft client letter. Tax Faculty members can download the full guide.

Features and articles

Companies encouraged to review loan relationships
  • Article
  • 07 Jul 2025
HMRC is asking companies where it has opened an enquiry into the application of the unallowable purpose rule to consider their position in light of recent court decisions.
Government consults on HMRC’s approach to dispute resolution
  • Article
  • 21 May 2025
The government is seeking views on options for improving HMRC’s approach to resolving disagreements with taxpayers, focusing on HMRC’s alternative dispute resolution (ADR) and statutory review processes.
HMRC turns spotlight on profit extraction schemes
  • Article
  • 01 Apr 2025
In its latest spotlight, HMRC warns companies not to use a scheme that uses advertising and marketing expenditure to reduce taxable profits and disguise employment income in the form of redeemable loyalty points.
Software company wins R&D tax relief case
  • Article
  • 23 Sep 2024
Having struggled to convince HMRC that expenditure it incurred on a software project qualified for research and development tax relief, the company was successful in its appeal to the First-tier Tribunal.
Exclusive How to deal with an information request from a third party
  • Article
  • 02 Aug 2024
In this, the final article in a three-part series looking at problem areas in practice, Karen Eckstein explores the issues to consider when dealing with a request for information from a bank or another adviser.
Exclusive Butler & Others v HMRC [2023]
  • Article
  • 17 Jul 2024
The result of a recent First Tier Tribunal case on a failed claim for 100% Business Property Relief (BPR) on an interest in a Limited Liability Partnership (LLP) which ran a wedding business will be of interest to members and rural businesses alike.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.

Exclusive HMRC Investigations Handbook
  • eBook
  • 2025
  • Mark McLaughlin
Guidance on all aspects of HMRC’s investigative work, to help practitioners with tax administration and compliance.
Exclusive Tax fraud: criminal investigations and litigation - direct tax
  • eBook chapter
  • 2025
  • Mark McLaughlin
  • HMRC Investigations Handbook
Guidance on HMRC's investigations involving tax evasion, to help practitioners with tax administration and compliance.
Exclusive VAT aspects
  • eBook chapter
  • 2025
  • Mark McLaughlin
  • HMRC Investigations Handbook
A chapter on VAT aspects of HMRC investigations, to help practitioners with tax administration and compliance.
Exclusive HMRC powers
  • eBook chapter
  • 2025
  • Satwaki Chanda, Steve Collings, Jacquelyn Kimber, Maria Kitt, David O'Keefe, Andrew Parkes
  • Corporation Tax
A full chapter providing practical guidance on HMRC powers, covering topics such as appeal procedures, documents and record keeping, time limits for raising assessments, HMRC correction of tax returns and HMRC action to counter tax avoidance schemes.
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You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.

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eBooks

The Library & Information Service provides a collection of eBooks as a benefit of membership. Please log in to access these titles. If you are unable to access an eBook, please see our Help and support or contact library@icaew.com.

Exclusive Compliance issues and transfer pricing disputes
  • eBook chapter
  • 2022
  • Jerome Monsenego
  • Introduction to Transfer Pricing
A chapter examining two administrative concerns linked to transfer pricing: the need to enforce certain compliance rules, and the prevention and resolution of cross-border transfer pricing disputes.
Exclusive VAT administration, appeals and interest
  • eBook chapter
  • 2021
  • Malcolm James
A high level overview of the framework of VAT administration covering appeals and the interest charged on VAT recovered through the raising of an assessment.
Exclusive Self-assessment enquiries, discovery assessments and investigations
  • eBook chapter
  • 2021
  • Malcolm James
Outlines the difference between HMRC enquiries under self-assessment and discovery assessments. The chapter also addresses settlements, penalties and criminal proceedings and lists the main criminal offences related to tax.
Exclusive Tax appeals and administration
  • eBook chapter
  • 2021
  • Malcolm James
This chapter introduces the UK system of self-assessment. It covers the submission of returns, notification of liability, penalties, appeals, payment of tax, record-keeping and tax claims.
Exclusive Tax treaty case law around the globe 2019
  • eBook
  • 2020
  • Michael Lang, Alexander Rust, Jeffrey Owens et al
This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 41 most important tax treaty cases which were decided around the world in 2018.
Exclusive Taxes evaded, avoided and reformed
  • eBook chapter
  • 2017
  • James Hannam
An overview of tax evasion and avoidance methods in the UK, with reference to some high-profile tax tribunal cases where legal avoidance schemes were exploited in ways not originally intended by the government or HM Revenue & Customs. The author also suggests some tax reforms that might lead to a 'fairer' system.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the terms of use set by our suppliers and any restrictions imposed by individual publishers. Please see individual supplier pages for full terms of use.

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Articles and books in the ICAEW Library collection

The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on tax appeals, disputes and investigations. A selection of recent books on this topic is set out below.
Closure notices: ending HMRC enquiries
  • Library book
  • 2025
  • K. Gordon
  • Claritax Books
This book examines the statutory rules and various practicalities relating to closure notices issued by HMRC, from the taxpayer’s point of view. The author explains how to obtain a notice and how to deal with it once it has been issued.
Tolley's tax cases, 2025
  • Library book
  • 2025
  • K. Walton
  • LexisNexis
An annual guide to tax cases, summarising all key court, Special Commissioners' and First-tier Tribunal decisions relevant to current direct tax legislation. This latest edition includes summaries of over 2,800 tax cases, from 1875 to the present day.
Tolley's VAT cases, 2025
  • Library book
  • 2025
  • L. Fallon, A. Millar, E. Thompson
  • LexisNexis
An annual guide to VAT cases. This latest edition includes summaries of over 4,000 court and VAT Tribunal decisions from 1973 to 1 January 2025.
Schedule 36 notices: HMRC information requests, 3rd ed.
  • Library book
  • 2024
  • K. Gordon
  • Claritax Books
This book examines the extent of HMRC's powers to obtain information and documents from taxpayers and certain third parties, as well as the associated safeguards and constraints. The author aims to assist readers in recognising and challenging information notices that are not within the law.
Taxpayer safeguards: rights and protections for individuals, 3rd ed.
  • Library book
  • 2024
  • K. Gordon
  • Claritax
This book explores in a practical manner the safeguards that are available for taxpayers when trouble arises with HMRC. The author covers the whole spectrum of protections – statutory, judicial, administrative, and so on.
A practical guide to tax disputes, 3rd ed.
  • Library book
  • 2024
  • A. Craggs, J. Hickey, J. Levy
  • Lexis Nexis
A guide to preparing for and taking part in a hearing in the tax tribunals or courts. Includes coverage of relevant legislation and case law, as well as various practical tips. This third edition takes account of several recent procedural changes.
Tax litigation handbook
  • Library book
  • 2024
  • Pump Court Tax Chambers
  • Bloomsbury Professional
An in-depth guide to all aspects of procedure in tax disputes, appeals and litigation, with commentary that is both technical and practical. This title is the successor to the previously published Hamilton on Tax Appeals.
Dispute resolution outside of the tax tribunal
  • Library book
  • 2024
  • X.M. Manzano, S. Duncan
  • LexisNexis
A Tax Digest exploring the different options available to taxpayers and their advisers for resolving tax disputes that have reached an impasse or that have been subject to a final decision by HMRC without resorting to the formal appeals system.

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Some of the content on this web page was provided by the Chartered Accountants’ Trust for Education and Research, a registered charity, which owns the library and operates it for ICAEW.