2023 saw HMRC lose some important cases with the courts, in a break from the past, favouring a more restrictive analysis of anti-avoidance measures and the limits of legislation. On the procedural side, the courts still prefer not to let taxpayers win through knock-out procedural blows – but sided with the taxpayer on an information notice.
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2023 saw HMRC lose some important cases with the courts, in a break from the past, favouring a more restrictive analysis of anti-avoidance measures and the limits of legislation. On the procedural side, the courts still prefer not to let taxpayers win through knock-out procedural blows – but sided with the taxpayer on an information notice.
If you are not a subscriber, subscribe now to read this content.
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