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Trends in HMRC behaviour

15 August 2022 / Richard Taylor-Whiteway
Issue: 4853 / Categories: Comment & Analysis
Surviving in a harsh climate

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 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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