Private client review for June 2023
This month, we comment on mixed results for the taxpayer concerning information notices, with a challenge against these involving a personal services company denied in Leen, contrasting with a taxpayer victory pertaining to privilege in Refinitiv. Two tales from the tribunal serve as a reminder that late appeals are not received warmly (in Tolla), but that "special circumstances" may prevail against late filing penalties (in Marano). Murphy brings clarity on how the courts will construe time limits in an extra-statutory concession and Bhaur serves as another reminder of the courts’ dim view of tax avoidance schemes. Finally, we comment on recent taxpayer statistics.