2010 review: dispute resolution

After five frenetic years of change in the world of tax dispute resolution 2010 has been a year of consolidation. The effects of the change of government in May have had a direct impact. Equally we are seeing the subject of the ‘tax gap’ moving from the world of tax periodicals and (occasionally) the business pages of the broadsheets to the arena of party conferences and street demonstrations.

Practitioners in the world of tax disputes have over the last five years had to grapple with the merger creating HMRC which gave rise to a definite change in emphasis and approach in particular for direct taxes. We have seen a wholesale review and modernisation of Powers Deterrents and Safeguards – implemented over the course of several consecutive Finance Acts – and the introduction of a new penalty...