Abstract
This paper considers which parties appeal in tax cases and which parties win such appeals. It adapts party capability theory to derive hypotheses concerning the relative advantages of (certain types of) taxpayers and HMRC, and how this may be affected by institutional factors, such as requirements for permission to appeal, and factors associated with the resources of the parties, such as legal representation. These hypotheses are then tested, using statistical methods, on a dataset assembled by the author of all appeals (including further appeals) from Special Commissioners' decisions since 1981. In doing such this paper both questions what the functions of an appeal system are, and whether the appeal system satisfies these, as well as addressing the question of whether certain large corporates enjoy favoured treatment by HMRC, which has been a recent issue of public concern in the UK.
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