- Reliance on HMRC manuals & the automatic issue of HMRC notices…with a nod to crypto currencies & IHT.
It is a matter of profound importance that taxpayers and professional advisers are able to rely on the published statements of HMRC in connection with their own tax affairs and the affairs of their clients. The very idea that we might not be able to trust the public statements of one of the most important and prestigious organs of government, must surely be unthinkable.
It is in this context that the recent decision of the Court of Appeal in Aozora GMAC Investment Ltd v HMRC [2019] EWCA Civ 1643 assumes some importance.
The case was all about whether the company was entitled to double taxation relief which had been refused by HMRC on the authority of s 793A of the Income and Corporation Taxes Act 1988 (ICTA 1988). The company said that HMRC’s interpretation of s 793A was wrong—but crucially, even if HMRC were
