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Resolving large business tax disputes: what more should be done?

Stephen Daly (King’s College London) reports findings from a recent study suggesting the need for greater transparency and training at HMRC, as well as a rebalancing of the tax administration framework.

Finality over tax affairs is important for both the tax authority and the taxpayer. It allows the tax authority to focus its resources on ongoing and future issues whilst it allows the taxpayer to continue to engage with their business. Uncertainty can affect business decisions and ultimately investment into the UK. 

Disputes about tax however are inevitable. The principle of finality underpins the need to ensure that these disputes are resolved as expeditiously as possible. Significant delays between HMRC closure notices and tribunal appeals are undesirable as are delays between disputes arising and enquiries being closed.

There are two broad issues that need to be tackled accordingly: resolving disputes once they occur and preventing their...

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