The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of the taxpayer. At a seminar hosted by PwC Legal in London on Monday, Sam Grodzinski QC, of Blackstone Chambers, highlighted the issue and explained how taxpayers should assess when a legitimate expectation argument will succeed.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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