Default surcharge and reasonable excuse
Validity of a discovery assessment
Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.
Hui Ling McCarthy (Gray’s Inn Tax Chambers) writes that abandoning a statutory appeal when HMRC considers the proper route to be a claim for judicial review is not a decision to be taken lightly, and may lead to unexpected and unwelcome consequences.
Reasonable excuse and ignorance of the law
Criminal conviction and proceedings in the tax tribunals
Reasonable excuse and late payment
Application to lift a bar to proceedings
Information notice in relation to bank statements
Jurisdiction of the FTT and legitimate expectation