How Tower MCashback could change litigation strategy

When the UK Supreme Court ruled in favour of HM Revenue and Customs (HMRC) in the Tower MCashback decision in May concerning capital allowances, many tax practitioners lamented what the Court seemed to be saying about the tax avoidance arguments that HMRC may advance during a hearing. The decision comes at a time when HMRC is entering into more enquiries and disputes with corporate taxpayers. Erin Kelechava investigates whether the case is yet another sign of a new era defined by more contentious relationships between Revenue and taxpayers.