Anne Redston

This Practice Note outlines the procedure for appealing to the First-tier Tax Tribunal (FTT) against a decision made by HMRC (tax appeals). This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note sets out how to appeal to the Upper Tribunal (UT) in a tax appeal from the First-tier Tax Tribunal (FTT). It covers practical and procedural issues and explains how to get permission from the UT to appeal to the Court of Appeal (CA). This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note outlines what happens after a taxpayer receives the First-tier Tax Tribunal (FTT) decision. It covers: the options, including textual corrections to the decision, asking for the decision to be set aside, and/or asking for permission to appeal the decision to the Upper Tribunal (UT); when a taxpayer is likely to be granted permission to appeal and costs. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note sets out the rules that apply in the First-tier Tax Tribunal (FTT) and the Upper Tribunal (UT) when a party requests that a case should be heard in private. It considers the general rule that cases should be held in public, the exceptions to that rule, and the position where HMRC makes a ‘without notice’ application. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note summarises the status tests, derived from case law, which determine whether a person is employed or self-employed. A person’s employment status has significant consequences for income tax purposes as well as for National Insurance contributions (NICs) purposes. This Practice Note was produced in partnership with Anne Redston, Barrister.

This Practice Note sets out the main differences between employment and self-employment. It discusses the effect of this distinction for tax purposes, including the timing of payment of income tax, National Insurance contributions (NICs), expenses, statutory payments, leave entitlements and (briefly) employment rights. This Practice Note was produced in partnership with Anne Redston, Barrister.

This Practice Note explains how to work out whether a person is employed or self-employed. It considers the National Insurance contributions (NICs) deeming rules, the contractual relationship between the parties, HMRC status determinations, together with how these can be challenged, and HMRC’s Check Employment Status for Tax (CEST) tool. This Practice Note was produced in partnership with Anne Redston, Barrister.

This Practice Note discusses the purpose of an HMRC review of a decision, the potential consequences of accepting, refusing or ignoring an offer of a review, the process of a review and the interaction with appealing to the First-tier Tax Tribunal (FTT). This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note explains how and when judicial review (JR) can be taken in the High Court against HMRC decisions or against tax legislation. It considers the procedural requirements and provides practical guidance. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note outlines what to do after a taxpayer has decided to appeal an HMRC decision to the First-tier Tax Tribunal (FTT), including up to the day of the hearing. It discusses the appeal form, the classification of the case by the FTT, pre-hearing directions, and preparing trial bundles, skeleton arguments and witness statements. It also discusses the considerations and approach required where oral evidence might be given from outside the UK. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note outlines how legal and professional privilege (LPP) applies in relation to tax matters. It considers the interaction between LPP and HMRC’s information and inspection powers and discusses the extent to which LPP is available for non-lawyer tax advisers. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note considers the main things to raise with a client when deciding whether or not to appeal to the First-tier Tax Tribunal (FTT) in respect of a tax matter. It discusses the proposed tribunal fees, payment of the tax in dispute, the merits of the case, privacy and confidentiality. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note sets out the procedures for using alternative dispute resolution (ADR) in a tax dispute with HMRC. It outlines the ADR process, explains when it is available and how to access it. This Practice Note also sets out the advantages and disadvantages of ADR when compared to litigation. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note explains how and when Judicial Review (JR) can be taken in the Upper Tribunal (UT) in relation to tax matters. It discusses the making of JR applications to the UT, the transfer of JR cases from the High Court to the UT, the procedure in JR applications made to the UT, the interaction with the FTT, and practical considerations if a dispute involves both public law and revenue law issues. This Practice Note was produced in partnership with Anne Redston, barrister.

This Practice Note outlines what happens at a First-tier Tax Tribunal hearing in respect of a tax appeal. It covers practical matters, including: who are the participants (including witnesses), where does everyone sit, how to address the tribunal and HMRC, the order of events, the difference between law, evidence and argument, and the types of decision notices. This Practice Note was produced in partnership with Anne Redston, barrister.