Originally posted by webberg
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Surely that has to be decided on a case by case basis.
An HMRC inspector can have an 'opinion' but it may not be valid.
If its just accepted that if HMRC say they have a new opinion & the validity of that opinion is never tested then its a get out of jail free card anytime they want to open an investigation and have left it too long.
The law itself becomes pointless if at anytime one party can win by saying "I have an opinion" and you just have to take their word for it.
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