---
title: "Crucial Issues in Tax Disputes: Event | The Barrister Group"
description: On September 5th, Exchequer Chambers, part of The Barrister Group, will host its first tax law seminar in the Inner Temple. The event will feature talks by a number of leading tax practitioners.
---

[The Barrister Group Blog ](https://thebarristergroup.co.uk/blog)

# [Crucial Issues in Tax Disputes: Event | The Barrister Group](https://thebarristergroup.co.uk/blog/crucial-issues-in-tax-disputes)

 Written by [The Barrister Group](https://thebarristergroup.co.uk/blog/author/the-barrister-group) | Jul 19, 2024 1:38:20 PM

On September 5th, Exchequer Chambers, part of The Barrister Group, will host its first tax law seminar in the Inner Temple.

The event will feature talks by a number of leading tax practitioners, and tickets can be purchased [here](https://thoughtleaders4.com/private-client/private-client-event/crucial-issues-in-tax-disputes/booking).

### Event Agenda

**9.00am - ****Registration**

 

**9.30am - ****Conference Opening Discussion on Key Lessons Learned from Disputes Practice**

- Panellists discuss each of the 5 key lessons learned in their respective practices
- Insight from highly experienced practitioners

**9.50am - ****Current Trends in Tax Litigation in the FTT, Upper Tribunal and Higher Courts ***(Andrew Thornhill KC - Barrister, Exchequer Chambers)*

 

- Key issues
- Key pitfalls

**10.10am - ****Tax Enquiries and Information Notices ***(David Francis - Partner, Grant Thornton)*

 

- Types of ‘enquiries’
- Strategy for resolution
- The importance of Disclosure
- Managing the information flow

**10.25am - ****Current Enquiry Trends / HMRC Investigations ***(David Francis - Partner, Grant Thornton)*

 

- Upstream compliance
- Topical trends
- Disclosure facilities

**10.40am - ****HMRC's Civil Approach to Tax Fraud ***(Annis Lampard - Tax Director, Deloitte & Karmjit Mader - Director, Deloitte)*

 

- What is Deliberate behaviour?  
- HMRC’s Fraud Investigation Service  
- Contractual Disclosure Facility - Code of Practice 9 
- Consequences deliberate behaviour – assessments, penalties and other implications.
- How is HMRC asserting deliberate behaviour outside of Code of Practice 9

**11.05am - ****Refreshment Break**

 

**11.15am - ****Discovery Assessments ***(Hugh Gunson - Partner, Charles Russell Speechlys)*

 

- Time limits
- Carelessness vs deliberate behaviour / causation
- “Acting on behalf of”
- The officer condition
- Practical points

**11.30am - ****First-tier and Upper Tribunal appeals: Case Preparation and the Hearing – Practice and Current Issues ***(Julian Hickey - Barrister, Exchequer Chambers & Judge Nigel Popplewell - Judge, First Tier Tax Tribunal)*

 

- Strategic review – key issues
- Key points on preparing and completing grounds of appeal (and making amendments)
- HMRC’s Statement of Case – key issues and particularisation
- Skeleton arguments / Purpose and preparation

- Key aspects of preparation: evidence / witness recollection / burden of proof / standard of proof – what the tribunal is looking for on the issues
- Case management issues through to the hearing
- Appeals – navigating permission to appeal in FTT and UT – what to look for and why
- Costs regime

**12.45pm - ****Panel Discussion with Morning Speakers**

 

**1.00pm - ****Lunch**

 

**1.45pm - ****Evidence and Disclosure ***(Harry Smith - Senior Associate, RPC)*

 

- Evidence / Relevance / Admissibility / Disclosure of documents: scope of legal professional privilege
- Undertaking a review of documents
- Inspection of documents: practical issues
- Witness statements
- Specific Disclosure Applications: purpose and limitations

**2.10pm - ****Alternative Dispute Resolution ***(Jesminara Rahman - Director, Tax Resolute)*

 

- Outline of ADR process
- Changes in ADR
- Key Issues
- Key Pitfalls

**2.35pm - ****Tax Planning and Dispute Avoidance ***(Peter Mason - Barrister, Exchequer Chambers)*

 

- Key issues
- Key pitfalls

**3.00pm - ****Refreshment Break**

 

**3.15pm - ****FTT Judges ***(Judge Nigel Popplewell - Judge, First Tier Tax Tribunal)*

 

- What characteristics you are likely to find in an FTT Judge before whom you appear

**3.40pm - ****Judicial Review and Tax Disputes: How to Challenge HMRC Discretion; What is Involved and Pitfalls ***(Richard Clayton - Barrister, Exchequer Chambers)*

- Key issues
- When available / Jurisdiction
- Grounds for Judicial Review
- Illegality
- Irrationality
- Legitimate Expectation
- Fairness
- Practice and procedure: High Court and Upper Tribunal
- Importance of pre-action protocol letter
- JR and Tax – key cases
- Key pitfalls and how to avoid them

**4.15pm - ****Alternative Remedies for Tax Disputes – What to do When Tax Goes Wrong ***(Hugh Gunson - Partner, Charles Russell Speechlys & Julian Hickey - Barrister, Exchequer)*

 

- Mistake and rectification – winding back the clock:
- Conditions
- “Artificial tax avoidance”
- FTT vs High Court – who has jurisdiction?
- UK vs offshore courts – differences in approach?
- Procedure
- Professional Negligence

**5.00pm - ****Panel Discussion with Afternoon Speakers**

 

**5.15pm - ****Conference Summation and Start of Drinks Reception**

 

**6.30pm - ****Conference Closes**

[View full post](https://thebarristergroup.co.uk/blog/crucial-issues-in-tax-disputes)

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