“HMRC insists that the era of aggressive tax avoidance by multinationals is over. This justifies the ‘co-operative compliance’ approach they take to very large businesses, unlike with ordinary taxpayers,” says Mike Lewis, director at TaxWatch. “Litigation is very rare, and available powers and penalties sit unused on the statute book. Though some large companies have undoubtedly changed their tax behaviour, this case raises the question of whether HMRC has ‘defanged’ itself when dealing with multinationals which do not co-operate.”
