Is 'conflicting out' worth the effort?
Family office lawyers explain why ‘conflicting out’ is a practice not just confined to TV show Succession - and why it's not worth the effort
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Family office lawyers explain why ‘conflicting out’ is a practice not just confined to TV show Succession - and why it's not worth the effort
Joseph Adunse looks at the Supreme Court ruling in HMRC and Raymond Tooth, which he describes as a 'comedy of errors'
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27 John Hood; Copyright Moore Kingston Smith The Raymond Tooth v Her Majesty’s Revenue and Customs (HMRC) Supreme Court decision is a landmark case for taxpayers and for those who advise them. Firstly, it clarified that even though the tax return submitted by advisers on behalf of Mr Tooth was technically incorrect, there was no attempt to mislead HMRC. Second, that once a discovery of error or omission in the tax return is made, the only time limits that HMRC needs to consider are those provided for in the taxes acts. Deliberate behaviour Mr Tooth had participated in a tax avoidance schem...