Relying on HMRC Manuals post-Hanover

Most tax advisers and many of their clients will at one time or another have drawn comfort from – or even placed absolute reliance upon – a statement made or confirmation given by HMRC in one of its many published Guidance Manuals. Advisers might also have assumed particularly in the case of a highly technical or arcane issue that there was no particular need to explain to the client that reliance had been placed on something included in a Manual.

It is certainly true that the degree of reliance placed upon the Manuals is likely to have depended on the topic or area of tax in question. Having recently carried out what seems to have become an annual scrutiny of the pages in the Capital Gains...