My thanks to the loyal reader who posted this behind the scenes account of how HMRC screw up and dishonour negotiations:
"At a meeting a few weeks ago, the senior HMRC staff who have been engaged in a FIVE YEAR negotiation with a major multinational were being beaten up by the CEO and CFO to explain why a deal everybody (foreign tax authorities included) had been happy with 3 months ago was now a non runner.This is not the way to handle things!
All they did was to mumble about "Governance Procedures" and look deeply miserable.
As far as we could make out, it had gone up the food chain and a summary been served cold to beings unfamiliar with the history and complexities.
And one or more of them had bellowed "I like it not!!!" because despite offering a large net cash gain for the UK Treasury over the coming years, a large current year offset and smaller repayment in respect of prior years would result.
So off to Litigation it is. HMRC will lose because their original stance was based on a near complete misunderstanding of the facts and a refusal to listen."
See you in four or five years.
Tax does have to be taxing.
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