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Contentious tax quarterly

Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).

The tax tribunals

The Tax Law Review Committee (TLRC) previously participated in the reform of the tax appeals system leading to the abolition of the Special and General Commissioners of Income Tax and the VAT and Duties Tribunal and their replacement in 2009 by the First-tier Tribunal (Tax Chamber) (FTT) and the Upper Tribunal (Tax and Chancery Chamber) (UT). As more than ten years have passed since the establishment of the new tribunal system the TLRC decided to commission a review of the operation of the FTT (the review).

The review is partly based on analysis of documentary evidence and on a survey of FTT users (mainly barristers and solicitors) conducted in December 2020 together with follow-up interviews conducted in February 2021. The review identified the following principal issues with the present system:...

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