An HMRC policy to target "deliberate tax defaulters" could prompt a wave of human rights cases against the taxman, a City law firm says.
The Revenue service is scrutinising the tax affairs of 900 individuals as part of its Managing Deliberate Defaulters Programme (MDD). HMRC have decided these taxpayers "deliberately pay the wrong amount of tax or no tax at all". The threshold for inclusion is ‘deliberate' understatement of tax, but if a taxpayer is advised to shelter income in what they believe to be an effective tax mitigation arrangement they could find themselves subject to the MDD. City lawyers Reynolds Porter Chamberlain say the MDD strategy appears to have been decided unilaterally by HMRC without Parliamenta...
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