What is abundantly clear to anyone who has a passing interest in the manner in which tax disputes are dealt with in the UK is that the legislation in Finance Act 2014, concerning accelerated and partner payment notices (the APN legislation), marks a significant shift in the rules of engagement between HMRC and its 'customers'.
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The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
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