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
