The blue touchpaper

I note with interest Mike Truman's report of the recent meeting held jointly by the Association of Revenue and Customs Officers (ARC) and the London Branch of the CIOT (Light blue touchpaper...) and Richard Davey's accompanying response to Mike's report.

Richard asserts that '[whereas under the current law there is the opportunity for aggrieved taxpayers to commence judicial review proceedings ] one of the objectives behind FA 2008 Sch 36 is to create a simpler and less expensive safeguard in legislating that HMRC have to act reasonably'.

One of the problems with Sch 36 (and the current direction of HMRC generally) is that legislating that HMRC must act reasonably is not always going to be of much help to taxpayers and their advisers.

First as I noted at the meeting itself (and as has been picked up by Mark Lee on the Tax Advice Network)...