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Email Exchange With HMRC Did Not Amount To A Binding Contract

By Mark McLaughlin, September 2018
An exchange of emails between HMRC and a taxpayer’s advisers did not contain the necessary elements to constitute a binding contract for settlement of the taxpayer’s liabilities arising from a tax mitigation scheme. 

Summary 

An exchange of emails between HMRC and a taxpayer’s advisers did not contain the necessary elements to constitute a binding contract for settlement of the taxpayer’s liabilities arising from a tax mitigation scheme. 

Background 

In the tax year 2007/08, the claimant invested in a tax mitigation scheme (‘the Scion Scheme’) that involved the purchase of certain rights in the well-known film ‘Frost Nixon’. 

The claimant subsequently submitted to HM Revenue and Customs (HMRC) self-assessment tax returns, which (among other things) contained relevant
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