Relying on HMRC Manuals post-Hanover

The recent decision of the First Tier Tribunal in Hanover Company Services v HMRC indicates that taxpayers cannot rely on the content of the HMRC Guidance Manuals for the purposes of the doctrine of legitimate expectation because of the so-called health warning in the introduction to those Manuals. The decision also suggests that, in any event, a taxpayer is not placing reliance on a practice of a tax authority where it is the taxpayer's advisers, rather than the taxpayer itself, who have consulted the relevant published guidance.