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Difference of opinion

18 May 2010 / Andy Wells
Issue: 4255 / Categories: Comment & Analysis
How can tax be lost if it is not due in the first place? ANDY WELLS is struck by recent Revenue thinking


  • Differences of opinion on tax issues contribute £6 billion to the tax gap according to HMRC.
  • Opposing HMRC’s constitutes ‘a behaviour’.
  • HMRC must be more accurate in their terminology.
  • Tax not legally due cannot be lost tax.

HMRC’s document Protecting Tax Revenues published on 9 December 2009 refers extensively to the ‘tax gap’.

I read it (yes I admit I am a sad case) and was surprised to find it referred to a tax gap arising from ‘taxpayers and HMRC taking different views of the law’: see for example paragraph 5.14 of the document.

This is not tax lost due to tax avoidance strategies as that is dealt with separately. It suggests that 15% of the tax...

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