Overview

Norton Rose explores whether the reality of HMRC’s new measures for large businesses, aimed at creating a more businesslike relationship between large corporate taxpayers and the tax collector, matched up to the organisation’s own publicity on the subject, or whether nothing much had changed.

With the merger of the Inland Revenue and HM Customs & Excise to form HMRC in 2005, the administrative functions of the two organisations have been gradually merged so that there is now broadly one set of rules applying to the collection activities of the merged organisation. HMRC have also taken the opportunity to introduce measures for large businesses aimed at putting the relationship between large corporate taxpayers and the tax collector onto a more businesslike footing.

As lawyers, we do not necessarily get a first-hand view of day-to-day dealings between HMRC and taxpayers, matters tending to have reached the dispute phase by the time we get involved. We therefore undertook this study in order to find out for ourselves whether the reality of the new measures matched up to HMRC’s own publicity on the subject or whether nothing much had changed. We also had the idea that our clients might be interested to learn whether their own experiences (good or bad) were typical or whether they have genuine grounds for grievance that the new measures do not apply equally well to them.

With the incoming Government looking set to clamp down on tax avoidance as well as raising cash in as many ways as possible, it will be interesting to see whether the trends identified in this report continue.

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