When HMRC seeks further powers to help them administer and enforce the tax system, they often assure parliament that they can be trusted to use such powers proportionately, because ‘We’re the good guys’. However, occasionally the ‘good guys’ behave in a way that prompts some criticism.

This article considers how HMRC behaved in one recent and lengthy dispute.

Unless order: HMRC barred from proceedings

The First Tier Tribunal (FTT) may issue what is generally known as an ‘Unless Order’. Such an order provides that, unless a party to a dispute complies with a direction, the FTT will order something, eg:

(1) to order the strike out of an appeal; or