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Closing Time for CTSA?

 
Craig Thomson senior manager Deloitte's Tax Risk & Resolution Group discusses the recent Special Commissioners' case of Jade Palace v HMRC
 
Given the pace of change in tax it is easy to forget that self-assessment (SA) has only been in place since the late 1990s. Despite this HMRC recently felt able to state the following: 'the enquiry regime for assuring compliance for direct tax returns is viewed by businesses tax agents and HMRC staff as inflexible and unnecessarily time-consuming' (from HMRC consultation document on Powers and Safeguards issued March 2006). From HMRC's perspective SA fits poorly with the need to integrate its business tax compliance efforts across all taxes. By contrast with both VAT and PAYE audits SA enquiries are often long-drawn-out affairs and can involve disproportionate time and...
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