It is a truth universally acknowledged that HMRC tax investigations can often take far too long to be resolved. Not only can it often take many months, if not years, to establish all of the facts upon which to base a sensible decision, but then technical positions and arguments can become deeply entrenched, with both sides seemingly unable or unwilling to move towards settlement.

Nowhere is this truer than where one of the aspects under enquiry involves participation in a tax avoidance scheme, where it is not at all unusual for an enquiry to run as much as a decade before it is eventually settled.