header-logo header-logo

08 January 2020 / Peter Vaines
Issue: 7869 / Categories: Features , Commercial , Tax
printer mail-detail

Taxing matters

13678
Peter Vaines puts HMRC in the dock & expects the truth, the whole truth & nothing but the truth
  • Reliance on HMRC manuals & the automatic issue of HMRC notices…with a nod to crypto currencies & IHT.

It is a matter of profound importance that taxpayers and professional advisers are able to rely on the published statements of HMRC in connection with their own tax affairs and the affairs of their clients. The very idea that we might not be able to trust the public statements of one of the most important and prestigious organs of government, must surely be unthinkable.

It is in this context that the recent decision of the Court of Appeal in Aozora GMAC Investment Ltd v HMRC [2019] EWCA Civ 1643 assumes some importance.

The case was all about whether the company was entitled to double taxation relief which had been refused by HMRC on the authority of s 793A of the Income and Corporation Taxes Act 1988 (ICTA 1988). The company said that HMRC’s interpretation

If you are not a subscriber, subscribe now to read this content
If you are already a subscriber sign in
...or Register for two weeks' free access to subscriber content

MOVERS & SHAKERS

HFW—Nelson Wang

HFW—Nelson Wang

HFW strengthens global insurance practice and Greater China offering with London Partner hire

Burges Salmon—David McEwing

Burges Salmon—David McEwing

Burges Salmon boosts Energy and Utilities practice with appointment of David McEwing

Browne Jacobson—Alexander Studholme

Browne Jacobson—Alexander Studholme

Browne Jacobson adds international construction arbitration partner in London push

NEWS
Law firm trainees are choosing US firms over their UK comparators, according to Chambers’ annual report on UK trainee satisfaction
A former senior judge has warned peers against scrapping juries for fraud and financial crimes, ahead of the Courts and Tribunals Bill’s second reading in the House of Lords this week
Civil practitioners face changes spanning debt recovery, workplace harassment and possession claims, alongside guidance on insolvency challenges and children proceedings

Finding matrimonial wealth is as challenging as dividing it, as family disputes draw practitioners into asset tracing, offshore structures and insolvency

Agreement between opponents offers no guarantee that a court will approve a retrospective increase to a costs budget
back-to-top-scroll