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HMRC Play Hardball: Part 1

 
In the first of two articles Robert Hartley and Greg Sinfield of the Lovells Tax Disputes Practice present the evidence of HMRC's changing relationship with large businesses
 
Over the last few months commentators have been analysing the raft of proposals coming out of HMRC on the reform of almost every aspect of the tax enquiry process. While it is important to be familiar with the detail of these reforms they are part of a more fundamental shift in HMRC's attitude to enquiries which hit the headlines recently when it was made public that HMRC has not only written to every FTSE 100 finance director about their company's relationship with HMRC but also that in one case HMRC set 150 officers on a single company's tax affairs. In this the first of...

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