Kyte – how to treat HMRC assurances that fall short of a contractual agreement
Taxpayers may settle tax disputes with HMRC by way of contractual agreement and the normal rules of contract law govern whether a binding agreement has been reached. However, the High Court's judgment in Kyte v HMRC [2018] EWHC 1147 (Ch) is a reminder that even when a taxpayer believes a dispute with HMRC has been settled, issues can sometimes still arise.
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