Last year Dave Hartnett the Permanent Secretary for Tax at HMRC took part in a Tax Journal roundtable discussion on dispute resolution (Tax Journal 19 April 2010) and among other things said this:
‘Behavioural changes are needed to make alternative dispute resolution work well. Taxpayers have to change their advisers have to change but tax administrations have to change most.’
In their subsequent article (‘View from HMRC: dispute resolution’ Tax Journal 10 January 2011) Geoff Lloyd who heads up HMRC’s Dispute Resolution Unit and Anthony Inglese General Counsel and Solicitor to HMRC demonstrated that HMRC are now embracing that change with a three-sided approach to...
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