Look at the list in the link below. Given the choice, you would have to be mad not to invest all your money in any tax avoidance litigation conducted by HMRC (above FTT so you get your costs). How therefore can there be any excuse that HMRC are starved of resources? I would be the first to invest in this (under PPP or whatever) given the chance!
https://www.gov.uk/government/publications/tax-avoidance-litigation-deci...
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"This is a list of litigation decisions where HM Revenue and Customs considered tax avoidance was involved and a decision was received during 2017 to 2018"
There is nothing that says the list is complete, or not selectively complied.
Am I getting too cynical?
Indeed...I don't know the numbers, but from what I hear especially recently HMRC have lost more IR35 cases than they've won. Unsure what their criteria are for the ones they list on that page, but I imagine it's conveniently chosen to show the results they want to show.
Check page 97 of the annual report for the basis of the statistics used to claim 80% success rate. HMRC count partial wins as wins with no mention of partial loss and then calculate a percentage from that. Is a partial win not the same as a partial loss and does the maths even work? https://assets.publishing.service.gov.uk/government/uploads/system/uploa...
Perhaps the Government realise that the claim for 'tax protected' is as reliable as all other HMRC estimates. The very term 'tax protected' immediately makes me suspicious as to how it was calculated. If you read the rest of the HMRC spin/report you'll probably see what I mean.
And yet, HMRC see hitting small businesses with MTD is going to plug the tax gap, as it is their 'mistakes' that causes the bulk of it!
If you look at the last page of the Annual Report, you'll find- "2.22 Making Tax Digital for Business was originally expected to generate £920 million of additional tax revenue by 2020-21 by minimising error and failure to take reasonable care through digital record-keeping and quarterly digital reporting. The government’s July 2017 decision to change the pace and scope of the roll-out meant that the additional tax revenue figures were updated accordingly (Figure 18). HMRC’s revised estimate of the additional tax revenue that Making Tax Digital for Business will generate by 2020-21 is £480 million and this was protected by the prioritisation exercise. HMRC expects Making Tax Digital for Business to have generated £1 billion of additional tax revenue by 2023. HMRC has identified that its Making Tax Digital for Individuals programme, that had no estimate of additional revenue, will now give rise to £293 million in additional tax revenue over the SR15 period.20 HMRC had realised £33.5 million of this by the end of March 2018."