Market leading insight for tax experts
View online issue

Large corporates and disclosure: beware ‘cheating the revenue’

Speed read

What is the difference between legal but unsuccessful tax avoidance and illegal tax evasion when both involve a liability which has not been self-assessed? Honesty. An unsuccessful avoider honestly believed that no tax was due. Honesty contains a ‘reasonable person’ test. As public opinion hardens around avoidance, juries are more likely to question whether a belief was properly held. Disclosure is key. Do you know what you need to divulge about complex planning and uncertain positions? The inadequate disclosure of unhelpful matters could be perceived as a dishonest attempt to ‘win’ without being fully drawn on the merits – and thus a ‘cheat’ on the revenue. HMRC might be on the look out for a case to take. 

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.