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Budget 2011: litigation, enforcement and compliance

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The Budget did not bring any major surprises on the contentious tax front. HM Treasury’s commitment to allocate large resources to close the ‘tax gap’ has now been reiterated on several occasions. That said, the concept of a list of tax avoidance schemes published by regulations and which carry higher risks for those who implement them could deal a serious blow to aggressive tax planning, while a new protocol on unscheduled changes to tax law was issued. In addition HMRC have hinted that they may be adopting a more pragmatic approach towards the settlement of tax disputes.

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