HMRC has published its latest report on the operation of the code of practice on taxation for banks. No banks have yet been determined to be in breach of the code, but HMRC states that a small number of banks ‘continue to push the boundaries of acceptable tax planning’. HMRC’s governance protocol requires an opinion from an ‘independent reviewer’ before a bank can be named. It has been advertising for reviewers, so it may only be a matter of time before someone is named. It is not always clear cut whether or not tax planning is contrary to the intentions of Parliament. In the absence of a formal appeal process, judicial review is likely to be used.
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