Budget analysis – Litigation, enforcement and compliance

Over the last few years there has been a very noticeable increase in HMRC's focus on tax litigation enforcement and compliance — in other words the steps HMRC takes to try to ensure that it collects the full amount of tax that is believes to be due largely under the auspices of the over-arching Review of Powers Deterrents and Safeguards which began in 2007. Since then we have seen reforms of HMRC's information gathering powers and ability to impose penalties to encourage compliance and penalise non-compliance. We have seen a war on avoidance a published 'litigate or die' attitude in certain cases and all manner of attempts to block 'attacks' on the system such as EU discrimination direct tax claims. This year's Budget was therefore all the more notable for the absence of...