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The Tax Law Review Committee has published an in-depth review of the First-tier Tribunal, highlighting concerns among current users over delay, lack of engagement and costs. The review is to be welcomed for its candid and sensible recommendations, and for highlighting the need for more judges and for judges being paid to sit for more days. There have also been two important Supreme Court decisions: one on the requirement for HMRC to initiate a formal enquiry and estoppel by convention, which largely approves the principles of the High Court in Benchdollar Ltd; and the other, Haworth, which undermines HMRC’s policy regarding the deployment of follower notices.
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