When considering whether to bring an appeal before the tribunals, reputational risk and taxpayer confidentiality are increasingly likely to be at the forefront of taxpayers’ minds. Liesl Fichardt and Robert Sharpe examine how such risks may be mitigated.
Legal professional privilege and engagement letters
Postponement of tax pending closure of enquiry
Reasonable excuse: reliance on accountant
Reasonable excuse for late submission of return
Richard Carson comments on the Upper Tribunal decision in HMRC v Lloyds TSB Equipment Leasing on a targeted anti-avoidance rule.
Exchange of information request
Freedom of movement
The Supreme Court decision in the civil case of Jones will herald a relaxation of the limitation on appeals to questions of law, and has already been wielded in recent tax cases, write Jolyon Maugham and Ryan Hawthorne
Alleged breach of confidentiality by senior HMRC official