Market leading insight for tax experts
View online issue

Relying on HMRC Manuals post-Hanover

Speed read

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.

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.