HMRC is now willing to negotiate means-based settlements with users of tax avoidance arrangements, such that the taxpayer is not required to pay the full amount of accrued tax and interest, according to law firm Stewarts.

The firm says that ‘HMRC has historically taken a rigid approach to settling tax avoidance arrangements,’ invariably requiring the avoidance scheme users to agree to pay the full amount of tax and accrued interest if it believed the planning did not work or had been defeated in the tax courts.

However, Lisa Vanderheide and Sarah Stenton, Directors in Stewarts’ Tax Litigation and Investigations team, say that ...