Giovanni Bracco, PwC LLP, and Agnes Quashie, PwC Legal LLP, explain the importance of documentation when implementing tax planning under the new powers regime
Giovanni Bracco PwC LLP and Agnes Quashie PwC Legal LLP explain the importance of documentation when implementing tax planning under the new powers regime
Since the publication of HMRC's Litigation and Settlement Strategy (LSS) in June 2007 HMRC has continued to develop an increasingly robust approach to investigating the fact pattern surrounding tax planning. This strategy has resulted in HMRC focusing on the quality of both the actual implementation and the documentation of that implementation. For example the LSS document says: 'Do not assume the facts are as described in the scheme. Check for implementation failure and always consider a penalty if an avoidance scheme fails because...
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Giovanni Bracco, PwC LLP, and Agnes Quashie, PwC Legal LLP, explain the importance of documentation when implementing tax planning under the new powers regime
Giovanni Bracco PwC LLP and Agnes Quashie PwC Legal LLP explain the importance of documentation when implementing tax planning under the new powers regime
Since the publication of HMRC's Litigation and Settlement Strategy (LSS) in June 2007 HMRC has continued to develop an increasingly robust approach to investigating the fact pattern surrounding tax planning. This strategy has resulted in HMRC focusing on the quality of both the actual implementation and the documentation of that implementation. For example the LSS document says: 'Do not assume the facts are as described in the scheme. Check for implementation failure and always consider a penalty if an avoidance scheme fails because...
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:
