More and more businesses are applying to take the taxman to a judicial review, because they think he made a decision that was unlawful.
In fact, the process saw a 31 per cent jump in applications made against HM Revenue & Customs during the most recent year for which figures are available.
In particular, 51 applications for judicial review were made against HMRC in 2012, up from 39 applications in 2011 and compared to a relatively static volume since 2008, according to law firm Pinsent Masons.
“HMRC may be getting tougher, but these figures suggest that taxpayers aren't willing to be steamrollered,” reflected the firm’s tax expert Jason Collins.
“The problem is that what HMRC sees as tax avoidance many businesses legitimately see as sensible business planning.
“And, with so much money now at stake as the Revenue tries to plug the tax gap and help reduce the deficit in the public finances, there's far more incentive for taxpayers who feel they have not been treated fairly not to give up without a fight.”