HMRC has published details of its latest settlement opportunity for those who have participated in specific avoidance schemes which seek to: use generally accepted accounting practice (GAAP) to write off expenditure or the value of assets to create losses either for sole traders, individuals or companies in partnership; access the film relief legislation for production expenditure; or create losses in partnerships through reliefs such as first year allowance, payments made for restrictive covenants or specific capital allowances. The settlement opportunity is subject to a number of restrictions, and HMRC retains the right to decline to include any particular case. It is arguable that there is a tension between this settlement opportunity and HMRC’s overarching litigation and settlement strategy.
