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Guide to Taxpayers’ Rights and HMRC Powers

Author: Robert Maas

Publication Date: February 2021

Publisher: Bloomsbury Professional

Law As Stated At: November 2020

Guide to Taxpayers’ Rights and HMRC Powers

Guide to Taxpayers’ Rights and HMRC Powers

Guide to Taxpayers' Rights and HMRC Powers, illustrates the growing breadth of HMRC powers which seem to increase every year as successive governments strive to counter tax avoidance and offshore tax evasion.

As this process continues, the rights of taxpayers become less evident and this book clearly lays out what these are, as well as the increasingly complex penalty regime for non-compliance and what steps practitioners can take on behalf of their client to challenge HMRC on any enquiries or decisions.

This update, as always, carefully compiled by Robert Maas of CBW takes into account Finance Act 2020 and also takes into account draft legislation published in July 2020 ahead of the following Finance Bill.

Cases on HMRC powers are now coming before the Courts and Tax Tribunals to such an increasing extent in the last few years that there seem to be more litigation on the exercise of HMRC's powers as on tax law itself. New cases to feature in this updated commentary are:

  • the Upper Tribunal guidance on reasonable excuse (Perrin) (para 12.104)
  • the Court of Appeal guidance on what is an inaccuracy (Tooth),(para 6.47) and
  • what is an assessment (Aria Technology Ltd) (para 6.218)