Impact of artificial intelligence on tax disputes

In the modern world society is always looking for improvements and automation to supposedly reduce costs and increase speed (indeed the author is indebted to the artificial intelligence (AI) system used to suggest the title for this article). This applies no less to the world of tax (as well as other forms of) litigation where adviser and legal fees can be difficult to stomach and the prospect of a brainy robot efficiently cutting to the chase may hold some appeal. A recent tax case however will have heartened AI-doom mongers who argue a reliance on AI is not always the smartest solution.

Felicity Harber (TC9010) is a decision of the First-tier Tribunal (Tax Chamber) from December 2023 relating to a penalty for a failure to notify a liability to capital gains tax (CGT). The taxpayer appealed the penalty on the basis that she had...