Wood v HMRC [2016] UKUT 346 (TCC)

Wills & Trusts Law Reports | October 2016 #163

In June 2010, Michael Wood admitted to under-declarations of income tax for the years 2002-03 to 2007-08 amounting to £743,424 and made a payment of tax of £352,983. This was made with a view to taking advantage of an HMRC disclosure opportunity for medical professionals called the ‘Tax Health Plan’, with a fixed tax geared penalty of 10% of the amount of tax under-declared. HMRC argued that the disclosure fell within the Tax Health Plan and opened a Code of Practice 9 investigation into his affairs. Michael Wood agreed to provide a disclosure report (the disclosure report) into his affa...

Tax Tribunal: The human face of tax

The conduct of Hamar at tribunal reveals valuable points of practice, as John Barnett explains ‘Arguing human rights in tax cases is notoriously difficult and we still await a significant case that shows where the boundaries of the state’s right to levy taxes lies.’ Like many tax advisers, I have taken cases to tribunal only …
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