In April 2000, the UK Inland Revenue published its revised proposals for a new power to apply for a judicial order to access certain documents. These may be required as evidence in any criminal proceedings connected to suspected serious tax fraud. The proposals are part of the Finance Bill being debated in the UK parliament, and so could change.
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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