The political and media focus on tackling avoidance has led both to the introduction of a range of new powers for HMRC to resolve tax disputes and to considerable pressure on HMRC to use those powers. Many of the new rules could be said to be too far reaching, with potential consequences beyond the ‘tax avoidance’ world. More than ever, taxpayers need to take care when dealing with contentious tax issues, whether as part of active disputes, an M&A transaction or day to day business.
