Settlement of tax liabilities

The taxpayer had invested in a scheme involving the purchase of film rights. He sought a declaration that he had entered into a binding contract with HMRC in January 2016 to settle his tax liabilities arising from the scheme. HMRC denied this.

The matter proceeded to the High Court.

It emerged that HMRC had earlier made an offer in writing to the taxpayer which he accepted but later withdrew this because of an error in the computations.

Chief Master Marsh said it was clear the taxpayer wished to settle and HMRC was willing to resolve the dispute by agreeing a calculated sum. However it was important to distinguish between a computation and a settlement offer.

The judge said: ‘The two may become synonymous but it is important to take proper account of the need for HMRC first to obtain relevant information from the taxpayer in order to make...