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PBR 2007 — Tax Appeal Reform

James Bullock McGrigors LLP reviews a consultation document relating to the future of tax appeals against decisions made by HMRC
It was all over in the blink of an eye. Suddenly we heard that the PBR was being brought forward from its usual slot in late November to the second day of Parliament's return following its summer adjournment. 'Of course — he's going to call an autumn election' we all said to each other.
In the fiscal world conversation then turned to the likely content of the PBR and in the contentious-tax world the smart money was on some form of restriction on restitutionary claims in the High Court relating to tax. This caused great excitement in particular at the 'ambulance-chasing' end of contentious tax. However as...

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