Estoppel prevents parties from departing from previous statements or promises and has been used in a number of tax cases. There are various types of estoppel, including estoppel by convention, issue or cause of action estoppel, and proprietary estoppel. Recent case law demonstrates that estoppel remains relevant in tax disputes; however, it is an area where HMRC seem to have had more recent success than taxpayers. Estoppel is a high threshold to meet, and it requires clear and convincing evidence of the circumstances between the parties, reliance and detriment.
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Estoppel prevents parties from departing from previous statements or promises and has been used in a number of tax cases. There are various types of estoppel, including estoppel by convention, issue or cause of action estoppel, and proprietary estoppel. Recent case law demonstrates that estoppel remains relevant in tax disputes; however, it is an area where HMRC seem to have had more recent success than taxpayers. Estoppel is a high threshold to meet, and it requires clear and convincing evidence of the circumstances between the parties, reliance and detriment.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
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