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Is is possible to make an ESC A19 claim stick, wonders TONY MARSHALL
KEY POINTS
- Does extra-statutory concession A19 protect those it was meant to?
- HMRC argue that end of year details are not information.
- When is a ‘process’ not a process?
- HMRC argue that a P800 is an administrative measure.
- Is it ‘plain and obvious’ that there is no right of appeal?
Like most general practitioners I’ve had little experience of what we used to call the General Commissioners – now the First-tier Tribunal – generally we prefer to sort things out with HMRC before they get that far.
But with the political and public mood swinging against tax avoidance the scene is set for less ‘sorting things out’ and more confrontation. The message has gone out to those at the front line of HMRC: concede nothing!
So it was...
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