What a carry-back!

Keith Gordon discusses a recent Court of Appeal decision concerning carry-back claims and how taxpayers can challenge HMRC’s view of the law

When working on the Tax Law Rewrite Project at the turn of the millennium, I was told that there had been a recent delegation to the Inland Revenue from the Japanese tax authority. According to the story I heard, the Japanese were asked how long it took for their country to get used to their self-assessment regime. On hearing that it took about ‘four to five years’, the UK hosts expressed considerable relief (given that Self Assessment had been introduced in the UK in April 1996). However, one of the Japanese visitors then clarified his answer: he had said ‘45 years’.