Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.
HMRC has a deliberate strategy of losing cases. A former permanent secretary said that if HMRC didn’t lose some cases it would not be doing its job properly as it would not be establishing the boundaries of the law. HMRC boasts a success rate of at least 80% rising to 90% in recent years. Is 2023 the year in which this win percentage started dropping back and will 2024 also see this win ‘inflation’ tamed further?
Many taxpayers and practitioners will recognise the move by HMRC towards stretching existing legislation to the max. It is not a surprise that HMRC has done this – for years the courts grappled with how far they could go with ‘purposive...
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Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.
HMRC has a deliberate strategy of losing cases. A former permanent secretary said that if HMRC didn’t lose some cases it would not be doing its job properly as it would not be establishing the boundaries of the law. HMRC boasts a success rate of at least 80% rising to 90% in recent years. Is 2023 the year in which this win percentage started dropping back and will 2024 also see this win ‘inflation’ tamed further?
Many taxpayers and practitioners will recognise the move by HMRC towards stretching existing legislation to the max. It is not a surprise that HMRC has done this – for years the courts grappled with how far they could go with ‘purposive...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
