Taxpayer confidentiality is at the heart of the tax system. So what happens where a tax dispute with HMRC involves two individuals and the matter can’t be resolved without some sharing of personal tax information? That is in essence what lies at the heart of Mitchell and another v HMRC [2021] UKUT 250 (TCC) (8 October 2021). The two individuals Mr M and Mr B were shareholders in companies which HMRC believed were deliberately understating their VAT liabilities. HMRC raised assessments running into seven figures and after the companies became insolvent HMRC used its powers to transfer the liabilities on the individuals on the basis that the inaccuracies in the companies’ returns were the result of deliberate behaviours by company officers. The problem here was that Mr M and Mr B each denied responsibility for any inaccuracies and blamed (overtly or by...
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