Fighting a lead case direction
The NCA and the raising of discovery assessments
Late filing and reasonable excuse
Refusal to give a ruling is not a decision
Default surcharge and human rights
HMRC’s high profile clamp-down on suspected tax avoidance has pushed the backlog of tax disputes waiting to be heard to a new record high of 27,246, with a particular surge in the number of high-value cases lodged with the Upper Tax Tribunal, according to law firm Pinsent Masons.
Recovery of tax wrongly refunded by way of discovery assessment
40% penalty upheld in the absence of a reasonable excuse
Application for a closure notice
Evidence of dishonest conduct