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Contentious tax quarterly: Summer 2025

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

Recent procedural decisions

Costs

Securing a costs award against HMRC remains a persistent challenge for taxpayers with a high bar for establishing unreasonable conduct. However the recent case of Advanced Hair Technology [2025] UKFTT 599 (TC) highlights a particularly egregious example of such conduct which the FTT rightly criticised and penalised through a costs award in favour of the taxpayer.

In that case the taxpayer’s application for a costs order on the basis that HMRC had acted unreasonably in the course of conducting an appeal was unusual in that it had been made at the invitation of the FTT itself.

The taxpayer had appealed...

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