While tax planning remains alive, taxpayers engaged in planning must expect to come up against a tax authority prepared to use extensive and intrusive powers of investigation and its full resources to challenge planning through the courts. Planning under this new regime is not for the faint-hearted.
HM Revenue & Customs (HMRC) is consulting on new powers to support its approach to tax compliance. As has been seen in many of HMRC’s initiatives since it was formed in 2004, the concept of compliance extends beyond mere compliance with the law, to analysing taxpayer behaviours and in particular the taxpayer’s approach to tax planning and the transparency of the taxpayer’s relationship with the tax authorities.
