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Landlinx, VAT and call options: HMRC’s famous public disaster

The treatment of call options had been considered settled for over 40 years, but HMRC now wishes to reimagine it. Chris Nyland (Gowling WLG) analyses the merits of HMRC’s logic and its actions.

HMRC has of late embraced a ‘customer’-centric language so it would do well to heed a famous case study in customer relations. It runs like this: a household name had long produced an established and well-received formula enjoyed by customers. At some point some boffins in the organisation touted a study suggesting that the organisation should jettison the original formula in favour of one that addressed a newly-perceived ‘threat’ head-on even though the revised formula tore up decades of consistent messaging to customers. The organisation switched formulas. But the study was defective the threat was a false positive and the switch wrought immediate damage on the relationship between the organisation and its now-jittery...

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