Under construction: Tax investigations

The Chancellor has announced the terms of the financial incentive for those who report serious tax avoidance or evasion, the Strengthened Reward Scheme. Between 2023 and 2024, there is estimated to be a tax gap of £46.8 billion between the amount of tax recovered by HMRC and the amount of tax due to HMRC. With a minimum threshold of £1.5 million in unpaid tax, the scheme aims to address the tax gap by specifically targeting large-scale tax evasion by companies, wealthy individuals, and offshore or avoidance schemes.

In Rachel Reeve’s Budget on 26 November 2025, the Chancellor set out plans, among other things a to tackle fraud within the Construction Industry Scheme (“CIS”) and announced a technical consultation “aimed at simplifying and improving the administration of the scheme”.

The United Arab Emirates (“UAE”) has joined in global efforts to improve transparency and compliance in the crypto sector by signing the Multilateral Competent Authority Agreement (MCAA) under the Crypto-Asset Reporting Framework (CARF). The framework is expected to be rolled out in UAE in 2027, with the first automatic exchanges of information with other tax authorities such as HMRC taking place in 2028.

The COVID pandemic was a difficult time for businesses,  and many legitimately relied on financial support provided through government schemes to help them to survive and retain employees. However, it is estimated by HMRC that circa £10billion was also lost as a result of incorrect applications and outright fraud.

On 11 September 2025, the Supreme Court handed down its judgment in The Prudential Assurance Company Ltd v Commissioners for His Majesty’s Revenue and Customs, a case that delves into the interaction between VAT group rules and the timing of taxable supplies. The decision has significant implications for businesses operating within VAT groups, particularly in relation to deferred consideration and success fees.

Waqar Shah, a Partner at Kingsley Napley, takes a closer look at the recent report by the Committee of Public Accounts on the cost of the tax system.

In Ashley v HMRC [2025] EWHC 134 (KB), Mike Ashley brought a claim against HMRC arising from an alleged breach of his data protection rights following the making of a tax closure notice. His claim succeeded, but how did he get there?

On 26 March 2025, in the Spring Statement, the Chancellor of the Exchequer set out her continued plans to raise money without raising taxes.  The aim is to raise over £1billion in additional tax revenue by 2029-30. 

The Budget proposals concerning inheritance tax on farms and farm businesses have understandably created a furore amongst farmers and landowners.  Both sides should be considering whether a compromise could be agreed.

Today, the new Labour government announced its eagerly awaited budget. In this special briefing our private client and tax experts consider what the announcements will mean for you, your family, and your business.

Waqar Shah and Andy Norris analyse the latest decision of the Supreme Court in the case of Professional Game Match Officials Ltd, which has been referred back to the First-tier Tribunal.

Our series focused on the settlement of disputes considers issues encountered by practitioners across a range of dispute resolution specialities. This article discusses the often overlooked tax implications when settling a claim, highlighting the need for both claimants and defendants to seek expert advice.

This has been one of the most anticipated / dreaded budgets for some time, with clear noises coming from Rachel Reeves that she is going to tax wealth. This has led to panic amongst anyone with investments, cash, valuable property, businesses and pensions. What does it mean for them and what should they do before the budget?

The new Labour government is expected to announce significant tax increases in the upcoming October budget. This follows Chancellor Rachel Reeves' revelation of £22 billion in unfunded spending.

Inheritance tax liabilities for the tax year 2021 – 2022 were the highest ever recorded at £5.99 billion, as confirmed by annual statistics issued by HMRC on 31 July 2024. Given the sums involved, it is unsurprising that inheritance tax is a particular area of focus for HMRC investigations, which are reported to have resulted in recoveries of £1.39billion in underpayments of inheritance tax over the past five years. 

The recent decision in Get Onbord Limited v HMRC [2024] UKFTT 617 (TC) provided some helpful guidance for taxpayers and HMRC on the First-tier Tribunal’s (“FTT”) approach to research and development (“R&D) claims and in particular, the levels of evidence that both parties need to provide.

The Chancellor’s statement yesterday highlighted a black hole in public finances. The Chancellor also reaffirmed Labour’s commitment not to raise income tax, NICs or VAT (beyond the addition of VAT to private school fees paid from yesterday in relation to the school term staring in January 2025).

Privacy and confidentiality in tax cases have always been important particularly where the taxpayer is someone in the public eye. Whilst a tax enquiry, or indeed litigation, does not mean that the taxpayer has ‘done something wrong’, there are certain negative inferences made by the public and media which could impact future opportunities for the individual or corporate involved. 

Taxpayers have the right to deduct input tax, but HMRC can deny this if it proves the taxpayer knew or should have known their transactions were linked to fraud. Recently, there has been a significant rise in HMRC correspondence denying input tax recovery on these grounds across various sectors. It is vital to address this issue carefully due to its serious potential reputational and financial consequences for businesses.

If someone dies domiciled in the UK for inheritance tax (IHT) purposes (or non-domiciled but with UK assets exposed to IHT), this is a tax that cannot be ignored.