Settling Large Tax Disputes
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| Author | : Great Britain. National Audit Office |
| Publisher | : The Stationery Office |
| Total Pages | : 52 |
| Release | : 2012-06-14 |
| Genre | : Tax evasion |
| ISBN | : 9780102977141 |
The National Audit Office has concluded, on the basis of an examination by former High Court tax judge Sir Andrew Park of five large tax settlements, that all five settlements were reasonable and at least one may have been better than reasonable. However, there were concerns about the processes by which the settlements were reached and over poor internal communication of the reasons for settlement which resulted in a loss of confidence in the settlements, both internally and externally. These large settlements are complex and there is no clear answer to what represents the 'right' tax liability. In each case, there was a range of justifiable positions the Department might have taken. The NAO's examination included consideration of whether the settlement in each case was as good as or better than the outcome that might be expected from litigation, taking into account the risks, cost, uncertainties and timescale of that option. It is not clear that all settlements were fully compatible with the Department's Litigation and Settlement Strategy. For instance, there are some disputes where the only possible outcomes are either that the taxpayer owes nothing or that it owes the full amount. In these circumstances, the Department's Litigation and Settlement Strategy does not permit 'splitting the difference'. The Department has acknowledged that its governance processes need strengthening and is introducing new arrangements, including the appointment of an assurance Commissioner, who will approve all large settlements
| Author | : Michael Lang |
| Publisher | : Springer |
| Total Pages | : 608 |
| Release | : 2002-09 |
| Genre | : Business & Economics |
| ISBN | : |
A wide variety of legal approaches and techniques are presented in detail. Includes 18 country reports - from 14 EU Member States plus Norway, Hungary, Latvia, and the Czech Republic - as well as additional essays on such topics as international tax arbitration, social security conventions, the jurisdiction of international courts, and World Bank/ICSID dispute settlement procedures as all of these may be applied to the resolution of tax disputers.
| Author | : United States. Internal Revenue Service |
| Publisher | : |
| Total Pages | : 4 |
| Release | : 1978 |
| Genre | : Tax collection |
| ISBN | : |
| Author | : American Bar Association. House of Delegates |
| Publisher | : American Bar Association |
| Total Pages | : 216 |
| Release | : 2007 |
| Genre | : Law |
| ISBN | : 9781590318737 |
The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 458 |
| Release | : 2015-10-05 |
| Genre | : |
| ISBN | : 9264241132 |
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
| Author | : Glen Loutzenhiser |
| Publisher | : Bloomsbury Publishing |
| Total Pages | : 1401 |
| Release | : 2022-05-05 |
| Genre | : Law |
| ISBN | : 1509959459 |
This is the 10th edition of John Tiley's classic textbook on revenue law, covering the UK tax system, income tax, capital gains tax, inheritance tax and corporation tax, as well as incorporating sections dealing with international and European tax, savings, charities, and - new to this edition - value added tax and stamp duties. The new edition has been comprehensively revised and fully updated with the latest case law, statutory and other developments, including the Finance Act 2021. The book's companion website provides bonus chapters on investment intermediaries, pensions, charities, and the UK's value added tax and stamp duties. The companion website will also supply annual updates to the print edition as well as study questions to help students navigate this complex subject. The book is designed for students taking modules in tax law in the final year of their law degree, or for more advanced courses. It is also a valuable resource for academics and professionals in the field. It provides an account of the rules as well as citation of the relevant literature from legal periodicals and some discussion of, or reference to, the background material in terms of policy, history or other countries' tax systems to give readers a contextual overview of the subject. Accompanying online resources for this title can be found at bloomsbury.pub/tileys-revenue-law. These resources are designed to support teaching and learning when using this textbook and are available at no extra cost.
| Author | : Great Britain. Parliament. House of Commons. Committee of Public Accounts |
| Publisher | : The Stationery Office |
| Total Pages | : 29 |
| Release | : 2015 |
| Genre | : Business & Economics |
| ISBN | : 0215085574 |
The Committee have made taxation a key area of focus during this Parliament and have published 20 reports on taxation and made over 100 recommendations to HM Revenue and Customs (HMRC) and HM Treasury aimed at improving HMRC's performance and strengthening confidence in the tax system. The Committee believe they have influenced the debate about multinational companies paying the appropriate amount of tax due, based on their transactions conducted within the UK; exposed serious problems with how the tax planning industry pushes aggressive tax avoidance schemes to businesses and wealthy individuals; helped to reform how HMRC tackles marketed tax avoidance schemes and settles tax disputes with large corporates; and challenged HMRC to provide a better and more even-handed service to customers. The Committee welcome the action that HMRC has taken in response to the recommendations and the progress that has been made. But much remains to be done; for example, HMRC must urgently transform its currently unacceptable levels of customer service. The Committee further welcomes the lead the UK Government has taken in this area on the international stage and call on the next government to continue this work and undertake to tackle both the industry and culture that surrounds and supports tax evasion and aggressive avoidance.
| Author | : Malcolm James |
| Publisher | : Spiramus Press Ltd |
| Total Pages | : 228 |
| Release | : 2017-09-04 |
| Genre | : History |
| ISBN | : 1910151440 |
This book is about two things: tax and power. The processes through which tax law is formulated, involve more than the formal legislative and judicial processes which result in statute and case law. Tax law is an expression of tax policy, which is subjective and a heterogeneous product of states, cultures and politics. Regarding taxation as a branch of either black letter law or orthodox economics ignore, or even deny, this subjectivity. This book explores the complex dynamics of the debates which inform tax policy, the interaction between tax and power and how power relations between various groups in society and between individuals and the state are manifested through tax system. This helps to explain why the rules, procedures and practices are all formulated to suit their interests of the most powerful groups in society. Taxation is a powerful lens through which to analyse relationships between individuals and the state, since history has shown that there is a longstanding power relationship between rulers and subjects, which is articulated through tax regimes. Tax can therefore be seen as a technology which mediates such tensions and relationships and the way that choices are made and conflicts are resolved can give valuable insights into societal power relationships.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 110 |
| Release | : 2013-07-29 |
| Genre | : |
| ISBN | : 9264200851 |
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.
| Author | : Dominic de Cogan |
| Publisher | : Bloomsbury Publishing |
| Total Pages | : 183 |
| Release | : 2020-08-06 |
| Genre | : Law |
| ISBN | : 150992356X |
This monograph looks at how tax is intertwined with constitutional law and the state in the UK. It looks at a variety of topics including tax devolution, scrutiny and reform of tax legislation, the protection of taxpayers and the domestic legal processing of international rules and problems. Tax Law, State-Building and the Constitution presents and interrogates five key claims. First, there is a clear overlap between the concerns of tax and constitutional lawyers. Secondly, the tax system is being deeply affected by the fast pace of constitutional change. Thirdly, decisions taken in the tax field are likely to have a reverse influence on the evolution of the constitution. Fourthly, these relationships are heavily context-dependent, with tax making all the difference to some ongoing constitutional controversies whilst having very little to do with others. Fifthly, by acknowledging tax as an important moving part within the contemporary constitution we might understand both tax and constitutional law a little better. The book therefore contributes to deeper theoretical debates on the identity of tax law as a discipline, the relevance of tax to public lawyers, the meaning of state-building in the recent history of a developed country and the importance of public finances to a wider sense of 'what is going on'. These are questions that ought to command the attention of tax and constitutional law academics as well as policy makers and reformers. Runner-up of the 2022 SLS Peter Birks Prize for Outstanding Legal Scholarship.
