.png)
.png)
Changing landscape
KEY POINTS
- Will HMRC’s win in ROOT2TAX give fresh impetus to forcing disclosure of tax avoidance arrangements?
- Withdrawal of money from a company without a tax charge.
- Disclosure requirements under FA 2004 s 306.
- Did the tribunal ask the correct question?
Readers will be all too aware of the way in which accelerated payment notices (APNs) have changed the landscape. The fact that taxpayers must pay tax in advance of an appeal has led to many of them settling. There is a huge psychological difference between litigating in the hope that no tax will be payable and litigating in the hope that it will be possible to recover the tax that has already been paid.
The main trigger for the issue of an APN is the disclosure of tax avoidance schemes (DOTAS) legislation. FA 2014 ...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
