The ever-growing challenge of managing tax disputes and risks

Tax authorities around the world remain under great pressure to tackle evasion and avoidance. In the UK, additional funding for HMRC’s counter-avoidance work promises not only more, but more intense, tax enquiries and litigation for taxpayers. The new partial closure notice provisions also add to the repertoire of tools that make handling those disputes more challenging for taxpayers. At the same time, the new failure to prevent the facilitation of tax evasion offences means that ‘tax’ will be on companies’ risk agendas, regardless of their own tax arrangements.