Tax disputes are a complex and often lengthy process, involving a variety of legal, procedural, and strategic considerations. For professionals tasked with advising on or managing these disputes, understanding the full spectrum of options available, from initial tax enquiries to formal appeals, is critical.

This course, presented by Julian Hickey of Exchequer Chambers, provides a comprehensive overview of the key stages in managing tax disputes and appeals, focusing on the transition from tax enquiry to appeal, effective use of alternative dispute resolution, and the strategic decisions that can make or break a case. We will also explore the jurisdiction and powers of the First-Tier Tribunal (FTT), discussing how to maximise opportunities within the review process, and the practical aspects of preparing appeals, including document disclosure, witness statements, and case management.

Our aim is to equip you with the tools to navigate this challenging process efficiently, avoid common pitfalls, and optimise outcomes for your clients, whether through negotiation, review, or formal appeal.

Prices: £195 + VAT for the first delegate. This is a per organisation price, so up to 10 of your colleagues from the same organisation can participate at no extra charge, even if they are viewing it from a different location or at a different time. So for example, if there are 10 of you the cost per delegate would be just £19.50 each.

All those attending will receive a free video recording of the course shortly after it takes place. You can participate in the course live or watch the recorded version whenever or wherever you want.

Overview

Tax disputes and appeals in overview

Key issues and pitfalls

Transition from tax enquiry to tax appeal: key points

1. Appeal v offer to review v options for Alternative Dispute Resolution
2. Key issues

How to obtain a closure notice
Scope of taxpayer right to apply for a closure notice

1. Jurisdiction and powers of FTT
2. Making the application

Dealing with an HMRC decision letter

1. Is there a right of appeal?
2. Maximising opportunities under the review process
3. How to deal with a late appeal

Notice of appeal and grounds of appeal

1. Appeal process for direct and indirect appeals
2. Key points on preparing and completing a notice of appeal
3. Key points on preparing and completing grounds of appeal - the opportunity to engage in written advocacy
4. VAT and hardship applications

Allocation of appeal

1. Standard and complex case allocation
2. Issues arising from allocation

Case preparation

1. Strategic review
2. Review of facts/documents
3. Preparation of chronology
4. Preparation of issues matrix
5. Review of law/statute/case law

Case management: common directions and request for bespoke directions

1. Directions timetable
2. Common elements: statement of case, list of documents, witness statements
3. Bespoke directions: statement of agreed facts, hearing date, expert witnesses, privacy of hearing, lead case application

HMRC statement of case

1. What to do on receipt of the statement of case
2. Requesting further and better particulars from HMRC
3. Reply to a statement of case

Disclosure: List of documents

1. Disclosure of documents: scope of legal professional privilege
2. Undertaking a review of documents
3. Inspection of documents: practical issues

Disclosure: Witness statements

1. How to take a witness statement
2. Interview of witness
3. 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

1. Key aspects of preparation
2. What to expect at the hearing
3. The tribunal: composition

Dealing with the FTT decision

1. Review of decision
2. How to appeal, if appropriate

Julian Hickey was called to the Bar in 1995 and he has been a partner with major City and West End solicitors’ practices. He is a highly experienced London Tax Barrister in Exchequer Chambers, specialising in HMRC tax enquiries, tax appeals, tax advice and related commercial disputes. With over 20 years of expertise, Julian advises corporations and private individuals on tax-related transactions, tax investigations and tax disputes with HMRC. Julian is highly experienced in representing clients in HMRC investigations and tribunals, as well as robustly defending, negotiating and managing appeals to achieve the best possible result. He has a proven track record of representing clients in high value and complex tax cases and is known for his discretion, practical thinking and approachable style.

To book a place on the course please click on the box at the top right. If you don't know all the names of your delegates, you can still book for those you know and add additional free delegates at a later date. All free delegates need to be registered in order to get joining instructions.

Important Notes about Booking

1. Payment can be made by credit or debit card or alternatively by invoice. The option to pay by invoice is below the pay by card option in the booking form

2. If you don't have the complete list of who will be attending you can book for those that you know will be attending and add the others at a later date

3. Please ensure that, when booking, you get colleagues' email addresses entirely correct as failure to do so will probably mean that they will not receive joining instructions

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