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Correspondence from readers on topical subjects.
Anton Lane offers some thoughts on HMRC’s changing investigations environment.
I recently spent six hours in the company of queen’s counsel (QC) debating technical issues around tax planning and of course discussing the change in environment at HMRC. The QC in question was excellent addressing tax risks openly and with sympathy to the practicalities of defending a client’s position.
It is worth mentioning that we almost always assume that whatever planning a client is undertaking to mitigate tax will these days be automatically challenged. This is not the case and some planning is still acceptable. However it is certainly the case that the environment within HMRC is changing. The summer budget included more steps to grow the culture of prosecution against tax crime and the push for greater disclosure to HMRC continues.
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