Key points
- The geopolitical and economic outlook is uncertain.
- The Treasury needs revenue to ‘balance the books’.
- HMRC is becoming more aggressive – 10% of requests for tax insurance relate to matters being investigated or contested.
- More tax enquiries settlements and litigation is expected.
Tax insurance ie insurance cover for identified tax risks by its very nature gives an insight into what gets a taxpayer’s heart racing (see ‘Uncertainty and risk’ Taxation 30 July 2020 page 22 tinyurl.com/2p8bjfwr). The concern may be around a difficult point of interpretation the amount of a tax risk increasing tax authority aggression or protecting against a worst-case scenario.
On the other hand roughly 10% of requests for tax insurance relate to matters being investigated or contested and practitioners receive a lot of information regarding tax authority behaviour. There is now...
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