A recent First-tier Tribunal decision adds a modern twist to an all-too-familiar story: a taxpayer appealing a High Income Child Benefit Charge (HICBC) assessment and losing. This time, the argument was drafted using artificial intelligence.
In Zzaman v HMRC [2025] TC 09520, the taxpayer used an AI tool to prepare his statement of case. While the tribunal acknowledged that relying on AI was a “logical and reasonable” choice for someone self-representing, it ultimately did more harm than good.
What Went Wrong?
Two key issues undermined the appeal:
- Irrelevant case law – The AI-generated submission included references to legal cases that were either irrelevant or unhelpful to the taxpayer’s position.
- Lack of explanation – Mr Zzaman couldn’t clarify or defend key parts of the submission under questioning, which weakened the overall argument.
Similar issues have appeared in recent cases such as Harber [2023] TC 09010 and Latif [2024] TC 09123, where AI-generated content lacked the legal depth and coherence expected by the tribunal.
The Wider Point on HICBC
As with many HICBC appeals, the tribunal stressed it cannot consider whether the law is fair; only whether it has been correctly applied. In this case, the discovery assessment under TMA 1970, s. 29 was upheld, and the taxpayer’s appeal was dismissed.
Why Expert Support Matters
This case is a stark reminder of the risks of handling HMRC enquiries without professional advice. While AI tools can seem like a quick fix, they’re no substitute for experience, technical expertise, and a deep understanding of the tax system.
That said, professional support comes with a cost, which is where tax enquiry fee protection proves its value. It covers the cost of us representing you in the event of an HMRC enquiry, giving you peace of mind and access to expert advice without unexpected bills.
If you’re not currently covered or would like to understand how tax enquiry fee protection could benefit you or your business, please get in touch with our team. We would be happy to talk through your options.
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