Rupert Shiers and Michael Conlon QC set out the likely areas for dispute in direct tax, indirect tax and transfer pricing for the year ahead.
Issues in UK tax dispute resolution have changed rapidly in recent years. In addition to the technical issues in various areas (discussed below) HMRC’s technical and policy approach has altered. In our view a key feature of tax disputes in 2014 will be the continued bedding-in of those changes within HMRC.
Two examples suffice. Senior large business service (LBS) individuals should become increasingly comfortable with HMRC’s Code of governance for resolving tax disputes republished in November 2013 especially with whether issues are sensitive enough for HMRC to require governance control regardless of the amount of tax at stake. We also expect the LBS to become increasingly proficient...
