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HMRC's latest settlement opportunity

HMRC has offered a settlement opportunity for participants in certain tax avoidance schemes. Jonathan Levy examines the detail, and suggests there is a tension between this settlement opportunity and HMRC's overarching litigation and settements strategy.

On 19 December 2012 HMRC published details of what they term a ‘settlement opportunity for participants in tax avoidance schemes’ (see www.lexisurl.com/f1Rk6).

HMRC intends to offer participants in certain schemes an opportunity to settle their tax liabilities by agreement. The invitation is extended to participants in schemes which seek to:

  • use generally accepted accounting practice (GAAP) to write off expenditure or the value of assets to create losses either for sole traders individuals or companies in partnership;
  • access the film relief legislation for production expenditure; or
  • create losses in...

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