ARTICLE
9 September 2025

Closing The Tax Gap: HMRC's Approach To "Legal Interpretation Disputes"

M
Macfarlanes LLP

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In this article for Tax Journal, Sarah Ling and Jackelyn West comment on the "Transformation Roadmap" for the modernisation of HMRC and the UK's tax administration which was published on L-Day (21 July 2025), focusing heavily on proposed measures to close the tax gap and stamp out non-compliance.
United Kingdom Tax

In this article for Tax Journal, Sarah Ling and Jackelyn West comment on the "Transformation Roadmap" for the modernisation of HMRC and the UK's tax administration which was published on L-Day (21 July 2025), focusing heavily on proposed measures to close the tax gap and stamp out non-compliance.

A brief but notable inclusion is the commitment to address “legal interpretation disputes”, that is, “cases where there is no avoidance but where the customer’s interpretation of the law, and how it applies to the facts of a particular case, result in a different tax outcome than that intended by the legislation”, to which HMRC attribute £5.4bn of the £46.8bn tax gap.

Read the full article.

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