HMRC will be able to depart from its own guidance if it believes that tax avoidance might be involved, as the decision in Samarkand illustrates. Jeanette Zaman and Owen Williams (Slaughter and May) consider the uphill struggle that taxpayers could face to prove they have a substantive legitimate expectation.
Gideon Sanitt (Macfarlanes) considers the decision in Ingenious Media and when HMRC may be excused from its duty of confidentiality.
The taxpayer cuts through a ‘procedural thicket’ to achieve victory in this retirement benefit scheme case, writes Adam Craggs
Pinsent Masons reports
Kevin Smith and Richard Doran look at the effect on taxpayers challenging HMRC by judicial review
James Bullock looks at the activist group's failed attempt to challenge HMRC