What taxpayers should know about bringing legitimate expectation claims against HMRC

The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of the taxpayer. At a seminar hosted by PwC Legal in London on Monday, Sam Grodzinski QC, of Blackstone Chambers, highlighted the issue and explained how taxpayers should assess when a legitimate expectation argument will succeed.