The challenges of multi-party litigation

Following growing parliamentary and public interest in the use of avoidance schemes the National Audit Office (NAO) published a report Tax avoidance: tackling marketed avoidance schemes in November 2012. The NAO report considered avoidance schemes used by large numbers of individuals and smaller businesses with some of the key findings being:

• the large number of users of mass marketed schemes presents a challenge to HMRC;
• HMRC’s investigations into the use of avoidance schemes can...