Time for the Civil Service (HMRC Department in particular) to be more civil!
The Barclays Service Corporation VAT group registration appeal makes for interesting reading.
Other commentators have commented on the substantive ‘fixed establishment’ point. I was concerned with the confrontational approach from both sides.
Eleni Hadjikakou, head of BSC UK branch was cross examined in relation to her involvement. She was ‘reticent’ when cross examined about the creation and purpose of the BSC UK branch. Surely, I suggest, a comment about tax efficiency would be appropriate! Taxpayers do have to be open and honest; otherwise HMRC will reach an obvious and negative conclusion.
Ms Hadjikakou declined to comment when asked about the significance of VAT to the formation of the BSC UK branch saying either that she had not been involved in the "discussions" and "conversations" or that she was not a member of the Barclays Tax Team.?
From the HMRC side, Elizabeth Hillman, ‘tax professional manager’ ?was frequently unable to recall matters, particularly those that appeared to criticise HMRC.
Her colleague, Debra Picksley, tried to assist. However, rather than giving evidence, she sought to advance HMRCs case and was reluctant to give answers which appeared to be contrary to it.
HMRC Officers are supposed to be Civil Servants working to assist taxpayers,?or at least to be even-handed. Such selective memory and half-truth as is evidenced here is unacceptable.
Cultural change required.
(Carefully descends from soap box!)
Forensic Accountant, Tax Consultant (UK/Spain), Finance Trainer (English, Portuguese and Spanish)
1 个月Such selective memory and half-truth as is evidenced here is unacceptable. ?? HMRC staff did not recall or give testimony that would go against HMRC ??♂?????♂?
Chartered Tax Adviser
1 个月At least they turned up! You would hope a tax authority would focus on getting the right result based on the facts and not doing whatever it takes to maximise revenue but here we are.