Dos and don’ts for a hearing at the First-tier Tribunal

The following is a familiar scenario for many tax practitioners. The adviser acts for a client during an enquiry and has been unable to persuade HMRC of the (hopefully) excellence of their arguments on the client’s behalf. The HMRC officer has now served a closure notice on the client. A review has been offered and the client duly accepts but unfortunately the review conclusion upholds the closure notice. This means that unless the client decides to ‘give up’ the next step is to appeal to the First-tier Tribunal (FTT).

In this practical article we focus on a number of key ‘dos’ and ‘don’ts’ of the litigation process borne of many years of experience navigating the – sometimes treacherous – waters of the tax contentious landscape.

Do – consider if litigation is worth it

Litigation of any complexity and that encompasses most tax issues ...