Choosing to represent yourself at a First Tier Tribunal (FTT) would probably be considered foolhardy enough. Yet, in a recent case, a taxpayer also chose to base their appeal against HMRC on artificial intelligence (AI), without human verification.
As you might expect, the results of these choices did not turn out in the taxpayer’s favour.
B Zzaman v HMRC
In April 2025, the FTT heard a case in which HMRC identified that Mr. B Zzaman didn’t notify the agency of his liability for the High Income Child Benefit Charge (HICBC) in 2018–2019, so HMRC raised a discovery assessment of an undeclared £2,501.
The FTT heard Mr. Zzaman’s appeal against this discovery assessment, which had been delayed due to uncertainties over whether HMRC could rely on a discovery assessment.
The government then legislated in the agency’s favour, meaning a discovery assessment can’t be used as the basis of a defence (although the application of this legislation is retrospective).
The taxpayer then represented himself using a defence that was written with the assistance of AI, but this defence was unreliable and not strong enough. For example, it:
- Claimed that HMRC should have notified him of the charge, when the primary responsibility for declaring tax liability lies with the taxpayer.
- Cited cases that, while not completely fictitious, were not relevant to the tax charge.
The taxpayer’s defence was therefore suspect, as the AI he used did not fully understand what was asked of it and did not provide accurate answers to support his case.
While AI can be used for research purposes, the results should always be checked for accuracy.
How does HMRC use AI?
HMRC uses AI extensively to help the agency analyse large amounts of data – for example, when a taxpayer declares income that’s insufficient to support their apparent lifestyle.
Landlords, in particular, should be aware that HMRC can use AI to search many databases – including listing websites, the Land Registry, and tenant deposit schemes – to establish whether the individual is declaring their property income correctly.
Though it’s intended for use by public bodies, the government has published an AI playbook that can be read online, which explains the limitations of artificial intelligence.
As the taxpayer in this case learned, to their own cost, relying on AI for tax expertise is likely to backfire. If you need tax advice, it’s best to speak to a qualified financial adviser.
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