Jennifer Knowlson and Richard Clarke of PricewaterhouseCoopers LLP Tax Investigations Network discuss the reliability of statements from and agreements with HMRC
The Court of Appeal recently heard the latest stage in the judicial review brought by Mr Robert Gaines-Cooper and others and the judgment is expected before Christmas. Mr Gaines-Cooper claimed to be non-UK-resident and believed that he could rely upon HMRC's published guidance in booklet IR20 (now rewritten as HMRC 6). HMRC disagreed and the Special Commissioners (SpC 568) pointedly noted that 'in this appeal we must apply the law rather than the provisions of IR20'.
The case raises once again the wider question of the extent to which a taxpayer can rely upon official HMRC guidance provided in whatever form.
HMRC publishes...
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Jennifer Knowlson and Richard Clarke of PricewaterhouseCoopers LLP Tax Investigations Network discuss the reliability of statements from and agreements with HMRC
The Court of Appeal recently heard the latest stage in the judicial review brought by Mr Robert Gaines-Cooper and others and the judgment is expected before Christmas. Mr Gaines-Cooper claimed to be non-UK-resident and believed that he could rely upon HMRC's published guidance in booklet IR20 (now rewritten as HMRC 6). HMRC disagreed and the Special Commissioners (SpC 568) pointedly noted that 'in this appeal we must apply the law rather than the provisions of IR20'.
The case raises once again the wider question of the extent to which a taxpayer can rely upon official HMRC guidance provided in whatever form.
HMRC publishes...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
