The first accelerated payment notices (APNs) have hit the doorstep but there are more schemes out there than HMRC can reasonably expect to clear up by any conventional means. Tax revenues will come in but the problem of how to clear up the 65 000 open schemes will remain. I know it is galling to many that ‘in the past HMRC did deals’ but the ‘dodgy deal’ was in many cases a myth. We have been confused by the decisions in Wilkinson [2005] UKHL 30 and Al Fayed [2004] STC 1703 neither of which had the full effect attributed to them and Sir Andrew Park’s report made it clear that compromise can be reasonable and lawful. It is easy to say that HMRC should have more resources but the real problem here is that HMRC’s shortage is not people (or even bright people) ...
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