Taking a Dispute to the First-Tier Tax Tribunal, Appeals and Demystifying Judicial Review
WORKSHOP: In-Person & In-Depth
10 October 2023 - Radisson Blu Edwardian Kenilworth, London
Agenda
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Registration
9.30am
Workshop Commences
10.00am
How to obtain a closure notice
- Scope of taxpayer right to apply for a closure notice
- Jurisdiction and powers of FTT
- Making the application
Dealing with an HMRC decision letter
- Is there a right of appeal?
- Appeal v offer to review
- Maximising opportunities under the review process
- How to deal with a late appeal
Notice of appeal and grounds of appeal
- Appeal process for direct and indirect appeals
- Key points on preparing and completing a notice of appeal
- Key points on preparing and completing grounds of appeal - the opportunity to engage in written advocacy
- VAT and hardship applications
Allocation of appeal
- Standard and complex case allocation
- Issues arising from allocation
Case preparation
- Strategic review
- Review of facts/documents
- Preparation of chronology
- Preparation of issues matrix
- Review of law/statute/case law
Case management: common directions and request for bespoke directions
- Directions timetable
- Common elements: statement of case, list of documents, witness statements
- Bespoke directions: statement of agreed facts, hearing date, expert witnesses, privacy of hearing, lead case application
HMRC statement of case
- What to do on receipt of the statement of case
- Requesting further and better particulars from HMRC
- Reply to a statement of case
List of documents
- Disclosure of documents: scope of legal professional privilege
- Undertaking a review of documents
- Inspection of documents: practical issues
Witness statements
- How to take a witness statement
- Interview of witness
- Form of witness statement
Agreed statement of facts
- Purpose and limitations
Skeleton arguments
- Purpose and preparation
Preparation for the hearing and at the hearing
- Key aspects of preparation
- What to expect at the hearing
- The tribunal: composition
Dealing with the FTT decision
- Review of decision
- How to appeal, if appropriate
Demystifying judicial review and tax disputes: uses, what is involved and pitfalls
The Decision Maker
- Who are the Judges?
- What is the Judge looking for in the First-tier Tribunal?
- What are Judges looking for on appeal (Upper Tribunal, Court of Appeal, Supreme Court)
Workshop Closes
4.00pm
9.30am
Registration
10.00am
Workshop Commences
How to obtain a closure notice
- Scope of taxpayer right to apply for a closure notice
- Jurisdiction and powers of FTT
- Making the application
Dealing with an HMRC decision letter
- Is there a right of appeal?
- Appeal v offer to review
- Maximising opportunities under the review process
- How to deal with a late appeal
Notice of appeal and grounds of appeal
- Appeal process for direct and indirect appeals
- Key points on preparing and completing a notice of appeal
- Key points on preparing and completing grounds of appeal - the opportunity to engage in written advocacy
- VAT and hardship applications
Allocation of appeal
- Standard and complex case allocation
- Issues arising from allocation
Case preparation
- Strategic review
- Review of facts/documents
- Preparation of chronology
- Preparation of issues matrix
- Review of law/statute/case law
Case management: common directions and request for bespoke directions
- Directions timetable
- Common elements: statement of case, list of documents, witness statements
- Bespoke directions: statement of agreed facts, hearing date, expert witnesses, privacy of hearing, lead case application
HMRC statement of case
- What to do on receipt of the statement of case
- Requesting further and better particulars from HMRC
- Reply to a statement of case
List of documents
- Disclosure of documents: scope of legal professional privilege
- Undertaking a review of documents
- Inspection of documents: practical issues
Witness statements
- How to take a witness statement
- Interview of witness
- Form of witness statement
Agreed statement of facts
- Purpose and limitations
Skeleton arguments
- Purpose and preparation
Preparation for the hearing and at the hearing
- Key aspects of preparation
- What to expect at the hearing
- The tribunal: composition
Dealing with the FTT decision
- Review of decision
- How to appeal, if appropriate
Demystifying judicial review and tax disputes: uses, what is involved and pitfalls
The Decision Maker
- Who are the Judges?
- What is the Judge looking for in the First-tier Tribunal?
- What are Judges looking for on appeal (Upper Tribunal, Court of Appeal, Supreme Court)
4.00pm
Workshop Closes
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