Ranga Nelson v The Commissioners for HMRC concerned discovery assessments and penalties for the years 2007/08 to 2012/13. HMRC had issued assessments based on the Appellant’s ‘deliberate’ behaviour in relation to the reporting of trading profit and the apparent shortfall of income compared with expenditure.
According to the HMRC annual report and accounts of 2017-18, 69% of individuals, small businesses and agents rated their overall experience with HMRC as positive. This begs the question as to why HMRC received 77,410 new complaints? Of these complaints, HMRC claim that 99% are resolved internally.
The government introduced a new General Anti-Abuse Rule (GAAR) in FA 2013 and it applies with effect from 17 July 2013. The primary objective of the GAAR is to deter taxpayers from entering into abusive arrangements and to counteract any tax advantage the abusive arrangements would otherwise achieve. GAAR comes into force when the arrangements […]