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The case law on legitimate expectation is wide-ranging and often complex, making it time-consuming to get to grips with the key guiding principles. This guide summarizes the key points to look out for when considering the circumstances in which a taxpayer may rely upon a representation made by HMRC, either in a publication or in a direct communication with the taxpayer. All cases necessarily turn on their own facts but it is hoped that this guide will be a helpful starting point.
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The comments made in this article are wholly personal and do not reflect the views of any other members of Monckton Chambers, its tenants or clients.