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Tax Investigations Update

 
Richard Clarke Director in PricewaterhouseCoopers' LLP Tax Investigations practice looks at current developments of relevance to practitioners who specialise in dealing with HMRC enquiries
 
The three recent developments featured here are:
 
●     a case concerning HMRC's right to access tax advice in the hands of a client;
 
●     two cases which show the limitations of trying to use procedural measures to end an enquiry; and
 
●     an HMRC statement which seems to herald a relaxation of its recent stance on the settlement of certain past PAYE liabilities.
HMRC access to tax advice
 
Very recently the Special Commissioners released an anonymised decision concerning the question of whether...

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