HMRC demands ‘further and better’ grounds for tax appeal

When HMRC asks for more information about a tax position, taxpayers should resist providing a response, as it may be a sign of over-reach as in the case of BGC over salaried member rules, warns Neil Tipping, lead tax enquiry consultant at Croner-i

It’s been a source of immense frustration for applicants to the First Tier Tribunal (FTT) recently that HMRC has applied for directions demanding ‘further and better’ particulars from the appellants in relation to their appeals before submitting their statement of case.

At best, this has been a delaying tactic, but at worst, it has sought to paper over the cracks where HMRC has failed to substantiate their decisions to assess taxpayers by attempting to make the appellants do their job for them.

On 9 June, Judge Redston issued judgment against HMRC on this very issue in the BGC Services Holdings LLP [2025] UKFTT 700 (TC) case.

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