But, what does this all mean?
The reality is that with this new approach by HMRC, if you’re going to challenge them alone you’re unlikely to be successful.
The right of appeal is going to be harder, as HMRC are doing everything they can to restrict this right and even when individuals and businesses make it to the point when their appeal is being considered, you have to be prepared for a long drawn-out battle, where success rates are still quite low.
My advice would be, that if you feel you’ve been wrongly approached by HMRC, make sure you get in contact with a tax and dispute resolutions team who have a proven record of settling complex cases and helping clients avoid criminal investigations and the confiscation of assets.
My comments on this topic were first published here in International Adviser.