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Pressure group’s demand fails

31 May 2013
Issue: 4405 / Categories: Tax cases

UK Uncut Legal Action Ltd v CRC, Queen’s Bench Division

Campaign group UK Uncut issued proceedings in December 2011 as a challenge of the agreement between HMRC and Goldman Sachs saying it infringed the tax department’s litigation and settlement strategy. The deal concerned National Insurance contributions due from the bank and had been the subject of a lengthy enquiry.

The claimant accused the Revenue of agreeing a package deal that took into account irrelevant considerations such as the potential embarrassment that would be caused were Goldman Sachs to withdraw from the government’s code of practice on taxation for banks.

The High Court agreed with Sir Andrew Park’s conclusions in the National Audit Office report Settling Large Tax Disputes that the agreement had not infringed HMRC’s litigation and settlement strategy. Each matter had been given separate consideration.

The judge concluded that “the settlement with Goldman Sachs was not a glorious episode in the history of the Revenue”; errors had been...

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