Are the scales weighted in Inland Revenues favour in a tax dispute?
This question presupposes that Inland Revenue and taxpayers are in a remotely comparable position, as if, for example, they were two individuals on each side of a contract. In reality, I think that there are fundamental differences, and some of the rules recognise these differences. Whether they give an unfair advantage to one party or the other in any given situation is often debatable. Some examples of the different positions are: • A taxpayer will have much more knowledge of the transactions in dispute than Inland Revenue. • As against that, Inland Revenue has very wide powers to obtain information and evidence. Complying with information requests can put a very heavy burden on the taxpayer. • There are a number of fixed deadlines, usually two months, by which taxpayers must respond to procedural steps in the disputes process. Failure to meet one of these deadlines will usually end the dispute in Inland Revenue’s favour. • Inland Revenue has a limited time within which it must compl
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