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23 October 2012 / Keith M Gordon
Issue: 4376 / Categories: Comment & Analysis , ESC A19 , Admin

P14s have counted as relevant information for the purposes of extra-statutory concession A19, discovers KEITH M GORDON


  • Problems with ESC A19.
  • Should P14s count as information received?
  • Earlier version of guidance counters HMRC’s current stance.
  • Will HMRC listen?

According to the saying when you are in a hole you should stop digging. The maxim might not have been followed by Harry Houdini but nor it seems do HMRC seem to abide by it.

Readers will be aware from previous articles such as my No ESCape and Paul McKay's Jumping the gun that HMRC have put forward proposals to revise extra-statutory concession (ESC) A19 in an attempt to “clarify” its meaning.

In No ESCape I described the proposals as “dishonest”. I hesitated before using such strong terminology but I felt on balance that the tone of...

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