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Private client briefing for November 2016

Andrew Goldstone and Stuart Crippin (Mishcon de Reya) review the latest tax developments affecting private clients.
 

Ingenious Media: confidentiality warning for HMRC

The recent unanimous ruling of the Supreme Court in R (Ingenious Media Holdings Plc) v HMRC [2016] UKSC 54 (reported in Tax Journal 28 October 2016) is important in clarifying just how careful HMRC has to be when dealing with confidential information relating to taxpayers and tax affairs.

HMRC had made information available to The Times newspaper regarding the activities of Ingenious Media Holdings plc as the promoter of a tax avoidance scheme. HMRC had not expected that The Times would publish details of the information and the Court of Appeal had agreed with the High Court last spring that HMRC was entitled to disclose such information. This was on the basis that disclosure was a justifiable means of seeking to combat tax avoidance schemes and reduce the numbers of taxpayers who may otherwise...

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