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INVESTIGATIONS


Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).
A growing number of taxpayers can expect to be involved in ‘early stage’ tax disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith) provide a practical guide for their advisers.
Andrew Park (Andersen in the UK) explains that HMRC must be properly resourced to embark on traditional tax investigations to increase funds for public spending.
Helen Adams (BDO) considers the ways the Supreme Court decision will change advisers’ approach to discovery appeals.

HMRC can’t wait forever to make a discovery assessment.

From taxing rights to dispute procedures, from employment taxes to VAT, Jason Collins and Catherine Robins (Pinsent Masons) consider the most pressing issues for the year ahead.
Jack Prytherch (Bird & Bird) discusses what HMRC will look for in an investigation and the steps MNEs can take to protect themselves.
Tori Magill (Good Cop9) examines the development of COP 9 operational policy and the investigation procedure in practice.

Loosening up access to information.

Sometimes you can be too relaxed.
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