SETTLING WITH HMRC IS RISKY

摘要

Although there has been a great deal of litigation over tax avoidance arrangements in recent years, many cases have not yet reached the courts. HMRC is keen to settle those cases, preferably without litigation and collect the tax. In the 2015 Autumn Statement, the government announced further 'settlement opportunities' for taxpayers and some resolutions have already been reached. However, settling with HMRC could result in some paying far more tax than they may ultimately owe. Settlements with HMRC frequently take the form of binding legal contracts. This means that even if judicial interpretation of the relevant tax law changes after the contract is signed, the settlement's terms remain in force, unless the parties agree to vary them or a court orders otherwise. There is no guarantee that either of those things would happen.