Ask an expert: ‘Lead case’ appeals

Question

My group entered into a tax avoidance scheme some years ago which was marketed by my accountants and sold to a number of their clients. HMRC is now challenging the scheme and we want to appeal HMRC's assessment. My accountants have said that as no one wants to run a case on their own the best way to defend the scheme would be for all their clients to enter into a formal ‘lead case’ appeal. We won't be the lead case but what will this mean for my group?

Answer

The rules

Your accountants might be thinking of one of a number of routes – including simply holding over your appeal whilst a single case proceeds to Tribunal – and you need to be clear on...