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08 January 2020 / Peter Vaines
Issue: 7869 / Categories: Features , Commercial , Tax
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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

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MOVERS & SHAKERS

Signature Litigation—Catherine Naylor

Signature Litigation—Catherine Naylor

International fraud and asset recovery offering boosted by partner hire

Stevens & Bolton—Alexa Payet

Stevens & Bolton—Alexa Payet

Private wealth disputes team adds contentious probate specialist

Morgan Lewis—Paul Feldberg

Morgan Lewis—Paul Feldberg

Firm strengthens investigations and sanctions capabilities with London partner hire

NEWS
Cheshire West, which established an ‘acid test’ for deprivation of liberty safeguards, has been overturned by the Supreme Court
The Chancery Division and other segments of the High Court are to be replaced by a new Business and Property Division (BPD), in a major civil justice shakeup
Law firms that hold client money will need to file annual accountants’ reports and make a declaration, the Solicitors Regulation Authority (SRA) confirmed this week
Two district judges and a tribunal judge have been sanctioned for delays in delivering judgments and orders
Private equity (PE) investment into UK law firms halved to £250m last year, but deal volume rose, according to research by Acquira Professional Services’ Momentum private equity market tracker
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