This week's opinion

The first skirmish in what is likely to be a long war of attrition about the scope and operation of the diverted profits tax has been heard in the High Court – Glencore Energy v CRC. This was all about procedure and did not decide anything of substance. But one part of the judgment stood out. The court asked HMRC to comment on what it considered its obligations in relation to formal submissions from taxpayers about their liabilities. This was asked specifically in the context of the diverted profits tax but HMRC responded more broadly:

‘HMRC considers itself always under an obligation to consider formal submissions from a taxpayer about the liability to tax.

‘HMRC is subject to a number of internal and external standards of conduct. HMRC has to act with integrity fairly objectively promptly and to rectify mistakes. HMRC operates an internal complaints...