13/11/08: HMRC’s new “Litigation and Settlement Strategy”

13th November 2008

In general, in acting on behalf of clients in disputes with HMRC, tax advisers have always sought if possible to negotiate good settlements with HMRC rather than allow the case to proceed to litigation. However, such an approach is likely to be more difficult under HMRC’s new Litigation and Settlement Strategy, which now applies across […]

12/11/08: HMRC defeat in MTIC case – Brayfal Ltd.

13th November 2008

In the recent decision of the VAT and Duties Tribunal in the appeal of Brayfal Ltd. (decision number 20781) regarding HMRC allegations of MTIC fraud through the operation of a fraudulent scheme known as contra–trading, the Tribunal identified the principle issues for determination as follows:   (i)                  that there was a tax loss in the […]