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Shocking
Key points
- HMRC refused to code out a taxpayer’s balancing payment which was less than £3 000 despite published guidance.
- The department later changed its stance without accepting it had been wrong.
- It seems ‘HMRC’s position’ might not represent the official view of the department but merely the view of the individual officer.
- Taxpayers and their advisers could be engaged in detailed correspondence with officers who are operating without oversight by the relevant technical specialist.
- HMRC must get its own house in order before dictating to professional advisers how they must conduct themselves.
I have written previously about a case which I first heard about from the Readers’ forum and have since written about it myself – see ‘Trust in the balance’ (Taxation 6 May 2021 page 20) and ‘Unbalanced’ (Taxation 26 January 2023 page 10). At the heart of the case was the...
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