Taxpayer Safeguards

When trouble arises with HMRC, it is essential to know what rights clients have in standing up to any real or perceived unfairness.

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About this work

This book addresses in a practical manner the question of the safeguards that are available in particular circumstances. The book covers the whole spectrum of protections – statutory, judicial, administrative, and so on – setting these against the background of the rule of law.

The impressive scope of this book ranges across HMRC powers generally, enquiries, reasonable excuse, appeals, human rights, double jeopardy, offshore matters, criminal offences, internal review, mediation, judicial review, the HMRC charter, vulnerable taxpayers, and much more.

The current author and the publishers acknowledge the meticulous work carried out by Robin Williamson, who created this book and who updated it for its second edition. We have together sought to preserve and build on Robin’s wisdom and insights.

“Very timely in setting out the whole position in a clear and structured way.” – from the Foreword to the first edition by John Cullinane, CIOT public policy director.

“A really good book!” – TAXline, October 2020.

Table of contents

• • Introduction

• • Information and inspection powers – safeguards and remedies

• • Assessments and self-assessment

• • Main penalty regimes and their remedies

• • Post-2012 powers and safeguards

• • Appeals, reviews and settlements [expanded by way of example]
    • Overview of the appellate process
    • Settlement agreements
    • Internal review [expanded by way of example]
      • Introduction
      • Beginning a review – direct tax cases
      • Conduct of review
      • Appeal to tribunal instead of or after review
      • Internal reviews – VAT
      • Are internal reviews worthwhile?
    • Mediation
    • Appeal to the tribunal
    • • Judicial review

• • Administrative remedies

• • Tax and the rule of law

• • Appendices