Exploring differences in interpretation of legislation, case law or guidance

We are carrying out research about differences of interpretation of tax law between HMRC and taxpayers.

We are carrying out research about differences of interpretation of tax law between HMRC and taxpayers. These are differences in interpretation of how the law applies to the facts of a particular case, which results in a different tax outcome, and there is no avoidance. Examples include categorisation, such as an asset for allowances, or VAT liability of a supply; the accounting treatment of a transaction; or the methodology used to calculate the amount of tax due, as in transfer pricing, or VAT partial exemption.

About the study

HMRC has a strategic objective to collect the right amount of tax, a key aspect of which is reducing the tax gap. A substantial portion (12%, or £3.7bn) of the tax gap is a result of differences in interpretation of tax legislation, case law or guidance . These cases are where the customer and HMRC’s interpretation of the law and how it applies in a particular case result in a different outcome, and there is no tax avoidance.

HM Revenue and Customs (HMRC) has commissioned NatCen to conduct research into businesses’ and tax agents’ views and experiences of situations where customer’s and HMRC differ in their interpretation of tax law. We are interested in the causes and potential solutions that HMRC can consider.

What will it involve?

To explore this topic, we will carry out interviews with businesses and tax agents who have had a case with HMRC in the last 12 to 18 months which we believe to be relevant.

Interviews will be conducted with a NatCen researcher at a time convenient for you in June, July, or August 2025. The interview will last up to 45 minutes. The interview will take place either by audio or video call (MS teams), whichever you prefer.

During the discussion you will be asked questions on the following topics:

  • Your role and responsibilities, nature of your business/clients and a high-level overview of your tax affairs/those of your clients
  • Your awareness and understanding of differences in interpretation of tax law
  • Your views of and approach towards differences in interpretation of tax law
  • Your previous experiences of differences in interpretation of tax law
  • The impact of differences in interpretation of tax law on your business or client
  • Your views on how HMRC can best reduce the number of differences in interpretation of tax law that arise.

Given that the interview will explore previous experiences of tax law interpretation issues and their impact on the business/client (including costs), you may wish to prepare for this in advance. 

Everything you say will be confidential and anonymous. Only NatCen will know you have taken part. We will not tell HMRC or anyone else what you have personally said or about compliance related to conduct. 

At the start of the interview we will ask for your permission to audio/video record the discussion (depending on whether you choose an audio or video call) to have an accurate record of what was said.

We will store your information securely and your details will not be shared with anyone else outside the research team or with HMRC. 

Reports and publications will not identify any individuals, businesses or clients. 
For more information on how your data will be used, visit the privacy notice.

Taking part in an interview will not affect your relationship with HMRC in any way. 

Why take part?

Your feedback is important. Your participation will help HMRC develop a better understanding of businesses’ and agents’ views and experiences of tax law interpretation, the impact of differences in tax law interpretation on them, and how best to respond to and help reduce differences in interpretation of tax law.

You do not have to take part if you do not want to, and you can change your mind at any time. If you do choose to take part, you do not have to answer any questions you do not want to, and you can stop the interview at any point.

As a thank you, you will receive a payment of £75, either in the form of a high street voucher or a donation to one of the following charities: Save the Children, Centrepoint and Alzheimer’s Society. 

Please note that not everyone who expresses an interest in the research may be able to take part.

Why have I been selected to take part? 

You have been invited to take part in an interview with NatCen because we would like to speak with businesses and agents who may have been involved in a case which we believe to be relevant within the last 12 to 18 months. HMRC records indicate that your business may have been involved in a relevant case or you may have dealt with a relevant case on behalf of a client during this timeframe. 

If you do not want to take part

Taking part is voluntary, and you are not obliged by your employer or HMRC to participate in this research. If you choose not to take part, it will not affect your relationship with HMRC.

Who is carrying out the research?

The National Centre for Social Research (NatCen) will be carrying out the research. The research is being carried out for the HMRC. 

Contact us

If you have any further questions or would like to discuss the research, please contact us using the details below. 

Email: LegalIntResearch@natcen.ac.uk 

If you would like to speak to somebody at HMRC about the research you can contact HMRC’s research team at: customer.research@hmrc.gov.uk  

If you have been contacted about this study and would like to verify its legitimacy, you can do so here: Check genuine HMRC contact that uses more than one communication method - GOV.UK