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Early stage tax disputes: a practical guide

A growing number of taxpayers can expect to be involved in ‘early stage’ tax disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith) provide a practical guide for their advisers.

February is an opportune time to reflect on some of the practical aspects of early stage disputes with HMRC. For many UK tax advisers February is associated with a long exhale after reaching the tax return season finish line. But as one tax return is filed a corresponding enquiry window opens. As enquiry windows commonly close on an anniversary of their opening the months preceding February also tend to see HMRC issuing a flurry of enquiry notices ahead of the statutory deadline with March then bringing HMRC’s practice of issuing ‘protective’ discovery assessments. We therefore find ourselves slap bang in the middle of HMRC’s peak activity in the early stage disputes lifecycle.

It is also an...

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