Monthly Archives: March 2018

Article in the British Tax Review

Consider the following example. A taxpayer has an assessment issued against her by HMRC. Her argument is that the tax is not due under the relevant taxing provision, or in the alternative that she is entitled to rely upon Extra-Statutory … Continue reading

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The LDF, legitimate expectations and conspicuous unfairness

The Court of Appeal has just handed down judgment in the case of City Shoes v HMRC, in which the taxpayers claimed to have a legitimate expectation as to certain treatment from HMRC. That treatment related to the ‘Liechtenstein Disclosure … Continue reading

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