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Alternative Dispute Resolution (ADR) success for Stephen Morse


08 October 2025


Stephen Morse was instructed to represent a taxpayer in their appeal against substantial assessments to deliberate penalties and to the offshore asset-based penalty under Schedule 22 Finance Act 2016. 

 

HMRC's case was that the taxpayer knew their tax return was wrong when it was filed. The appeal raised issues of domestic and overseas company law and employment law, alongside the interaction between different Capital Gains Tax reliefs. The facts were complex but largely undocumented. 

 

Following the submission of relevant evidence and an ADR hearing, HMRC have withdrawn the deliberate penalty assessments and the offshore asset-based penalty. 

 

Stephen was instructed by Harriet Turner, Associate Tax Director of Crowthers Chartered Accountants. 



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