Market leading insight for tax experts
View online issue

What can you legitimately expect?

Speed read

The starting point to any legitimate expectation claim is the criteria set out by Lord Justice Bingham in MFK Underwriting namely that a statement must be ‘clear unambiguous and devoid of relevant qualification’ to found a legitimate expectation. In considering whether the MFK criteria are met one must assume a hypothetical ordinarily sophisticated taxpayer and it is irrelevant whether the claimant is in receipt of professional advice. Increasingly HMRC publications assert that no reliance may be placed on statements therein for tax planning purposes. However where this

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.