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 new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap