Key Benefits
- Handle tax enquiries, appeals, and reviews more confidently by understanding key procedures, options, and common pitfalls
- Prepare stronger cases through better evidence review, appeal drafting, witness statements, and hearing preparation
- Navigate tribunal and judicial review stages more effectively, with clearer judgement on process, strategy, and available remedies
Do You Need to Attend This Course?
This Tax Disputes course is relevant to all lawyers, accountants, tax practitioners whether in private practice or employed in house, and general legal practitioners.
Accountants and Chartered Accountants working in practice or in-house
Tax advisers and consultants, including those involved in planning and structuring
Private client, corporate tax, and trust professionals
Legal professionals with clients receiving tax or accountancy advice
Compliance officers and risk managers in accountancy or tax firms
Trainees and junior professionals looking to understand professional responsibilities and risk exposure early in their careers
Technical Content
Overview
Tax disputes and appeals in overview
Key issues and pitfalls
Transition from tax enquiry to tax appeal: key points
Appeal versus offer to review versus options for Alternative Dispute Resolution
Key evidential and legal issues to identify and evaluate
How to obtain a closure notice
Scope of taxpayer right to apply for a closure notice Jurisdiction and powers of FTT
Making the application
Dealing with an HMRC decision letter
Is there a right of appeal?
Maximising opportunities under the review process
How to deal with a late appeal
Notice of appeal and grounds of appeal
Appeal process for direct and indirect appeals
Key points on preparing and completing a notice of appeal
Key points on preparing and completing grounds of appeal - the opportunity to engage in written advocacy
VAT and hardship applications
Allocation of appeal
Standard and complex case allocation
Issues arising from allocation
Case preparation
Strategic review
Review of facts/documents
Preparation of chronology
Preparation of issues matrix
Review of law/statute/case law
Case management: common directions and requests for bespoke directions
Directions timetable
Common elements: statement of case, list of documents, witness statements
Bespoke directions: statement of agreed facts, hearing date, expert witnesses, privacy of hearing, lead case application
HMRC statement of case
What to do on receipt of the statement of case
Requesting further and better particulars from HMRC
Reply to a statement of case
Disclosure: List of documents
Disclosure of documents: scope of legal professional privilege
Undertaking a review of documents
Inspection of documents: practical issues
Disclosure: Witness statements
How to take a witness statement
Interview of witness
Form of witness statement
Agreed statement of facts
Purpose and limitations
Skeleton arguments
Purpose and preparation/drafting/limitations
Preparation for the hearing and at the hearing
Key aspects of preparation
What to expect at the hearing
The tribunal: composition
Dealing with the FTT decision
Review of decision
How to appeal, if appropriate
Demystifying judicial review, and tax disputes: uses, what is involved and pitfalls
Jurisdiction / Public Law / FTT
JR Claims in overview
Pre-action protocol letter and reply / drafting and what to address
Grounds for Judicial Review
Statement of Facts and Grounds
Witness Evidence
Permission Stage
Oral renewal hearing
Full hearing
Case Studies - Practical case studies and examples will be included throughout the day.
Training Objectives
Redcliffe's Tax Disputes training will teach you the following:
When to appeal: advantages and disadvantages for the client
Key points to discuss with clients considering an appeal
How to appeal
Key points to prepare for an appeal
Common pitfalls to avoid
Key points in dealing with tribunal directions for standard and complex category cases
Settlement opportunities
When to use Judicial Review, scope and nature of the available remedies
Training Course Summary
This course provides a practical overview of tax disputes and appeals with HMRC, covering the full process from enquiry through to tribunal proceedings. It focuses on key procedural steps such as making appeals, using alternative dispute resolution, and preparing cases for the First-tier Tribunal.
It also covers essential case preparation skills including evidence review, disclosure, witness statements, and drafting grounds of appeal, as well as understanding tribunal procedure and hearings.
The course finishes with an introduction to judicial review in tax disputes and its role alongside tribunal appeals, supported by practical case studies throughout.
Your trainer
Course Trainer · 10 yrs experience
- Corporate Tax Courses
The lead trainer for this course was called to the Bar in 1995, he brings a wealth of experience gained from a distinguished career that spans both the independent Bar and senior positions within leading City and international law firms. He has also worked in New York and the Cayman Islands. His practice is dispute-led, with a strong emphasis on the intersection between legal, commercial, and tax issues.
He is a specialist in tax law and its associated fields, including commercial chancery, equity, company law, cryptocurrency and digital assets, partnerships, insolvency, and professional negligence. He advises on complex investigations and appears regularly for corporate entities, individuals, and HMRC at both trial and appellate levels. Much of his work involves high-value or technically challenging disputes, often arising from cross-border transactions or cases with voluminous documentation. He also has experience advising and representing individuals in matters involving allegations of fraud, including criminal tax investigations.
The trainer was awarded a Ph.D. (University of London) in Tax Law relating to intellectual property and its exploitation. He is co-author of Taxation of Intellectual Property (Bloomsbury Publishing), A Practical Guide to Tax Disputes (Lexis) and Internet Business (Commerce and Tax) (Jordans).
He is ranked as a Leading Practitioner in Chambers UK Bar 2025 and has particular expertise in areas such as corporate structures, partnerships, intellectual property, trusts, and insolvency, allowing him to provide strategic, commercially attuned advice across a broad range of contentious and non-contentious matters.
He appears regularly in courts and tribunals across the UK, including London, Manchester, and Edinburgh, acting both as sole counsel and as part of larger legal teams. The course co-presenter is a dedicated tax specialist 'Pupil Barrister' with a rapidly developing practice encompassing a broad range of domestic and international tax matters. He read law at the age of 17 and was a Vice Chancellor International Scholar at Cardiff University. He was called to the Bar by the age of 21. Alongside his Bar studies he was working under a pre-eminent tax silk in the country.
Reviews
No reviews yet for this course. Check back soon.
FAQs
Frequently asked questions for this course will appear here soon.