On 1 November HMRC published a new code of governance for resolving tax disputes. This is a key part of HMRC’s new governance arrangements for significant tax disputes announced by Lin Homer HMRC chief executive in February this year. The new governance arrangements have been prompted by criticisms of HMRC’s handling of large tax disputes including by the Public Accounts Committee in its report in December 2011.
The new code means that significantly more cases will be escalated for scrutiny within HMRC before an out-of-court settlement is agreed. This raises a number of concerns. Will HMRC officers be less willing to work collaboratively with taxpayers to find mutually acceptable solutions given the increased scrutiny to which their work will be subject? Will the new governance arrangements lead to further delays in disputes being...