Keep up to date with all things tax law related with the Pump Tax Chat, brought to you by leading UK tax set, Pump Court Tax Chambers. In our latest episode, Laura Poots and Ben Elliott discuss the latest case law developments in HMRC’s powers of assessment, for both direct and indirect tax. They cover issues of carelessness, deliberate behaviour and protective assessments. 

All the legislation and cases mentioned in the podcast as well as a transcription of the episode can be found on the podcast page on our website here.

You can find out more about Pump Court Tax Chambers here and on the speakers here:

Laura Poots / LinkedIn

Ben Elliott / LinkedIn

Laura 0:09

Welcome to Pump Court Tax Chat podcast series brought to you by the barristers at Pump Court Tax Chambers. We are the premier UK tax set and our podcasts aim to give you insight into recent developments in tax law and procedure. Across the series we'll take a look at a range of topics covering issues that arise both in disputes and in advising clients more generally.

Laura 0:30

All of the cases and the legislation mentioned in each podcast are set out on our website in the listing for that particular recording. If you have any questions please do contact one of our staff team. You can find their details on our website pumptax.com.

Laura 0:52

Welcome to the very first podcast in our series Pump Court Tax Chat. Listeners may be aware that Pump Court Tax Chambers has recently published a tax litigation handbook and so we thought it would be sensible to start off our series by talking about some developments in litigation since we published that book because of course it is a never-ending topic of discussion. I am Laura Poots and joining me is my colleague Ben Elliott who is one of the editors of that book. Ben you spent the best part of last year and maybe much more time before that editing our book on tax litigation.

Why should our listeners care about all these geeky procedural points on litigation?

Ben 1:37

That's a very good question. I find it all very interesting and I think the first reason is simply tax procedure is all about, if we really step back here, it's about the balance between the state, the UK government and the citizen. Parliament has said yes HMRC you can go off and you can go collect all this tax and the citizen has to pay money to the state.

But in order to provide fairness between the state and the citizen, parliament has put in place checks and balances that work both ways. So for example if a taxpayer has made a mistake in their return and they want to correct it they are subject to certain time limits by which they're allowed to amend their return. In the same way if the state wants to impose liability and wants to take money from a citizen then parliament has said yes you can do so but it's not enough to show that tax is actually due. You HMRC also need to go through these various steps, you need to jump through these hoops and you need to comply with the requirements of these checks and balances and the most obvious one is time limits. If you put in your tax return and you've taken a reasonable position and an honest position then HMRC can only pursue you within certain time limits, usually four years. So I think it's very important in that sense.

I think also though, it gives rise to many many interesting issues. I mean concepts such as carelessness, causation, deliberate context. Deliberate is really important because as we're going to come on to, deliberate comes and has these connotations of fraudulent as well and the revenue now have multiple powers. There are many taxpayers who wouldn't care about a penalty for example, except that now under the new deliberate default regime their names can be published to the world at large and I've had clients who have come and I've had to fight cases solely because the person they say yes I'm happy to pay the amount but I do not want HMRC saying I'm a deliberate defaulter. It's a very serious allegation, it's something which is pseudo-criminal and we know the border between HMRC alleging deliberate conduct at someone and referring it to their criminal colleagues sometimes that can be a very difficult issue. We can't really tell why they do one or the other so it's all very important.

3:45 Laura

I think I'd also add maybe this is the slightly more money focused way of looking at it that sometimes these points result in quite surprising wins for taxpayers with a lot of money at stake and wins that weren't obvious when the litigation started. I think we're going to see at least one example of that in the cases that we look at today but there have been many more before it. So you've mentioned all of HMRC's powers and the limits on those powers. We're going to focus on assessments today which is always an area ripe for litigation and we're going to look at three cases all tied to different powers of assessments and we're going to start off with Mainpay.

So Mainpay in the upper tribunal is a case about PAYE determinations some of which were only issued in time if the loss of tax had been brought about carelessly by the taxpayer and the specific issue concerned the question of causation i.e. did the carelessness bring about i.e. cause the loss of tax and that was in a context where the alleged carelessness was that the taxpayer failed to take adequate advice in relation to the effect of certain contracts that were said to be critical to the tax treatment. And that's a very important issue generally because causation issues arise when considering the validity of assessments and determinations and also looking at time limits and similar issues arise in relation to careless penalties as well.

Okay so that's the issue before we get into Mainpay itself have there been previous cases which have looked at this question?

There are a number of recent cases that have looked at this causation issue but with very different approaches and outcomes.

So the high watermark for taxpayers was probably Strachan at first tier tribunal level in which the tribunal held that the taxpayer should have taken further advice before filling out their tax return and the issue in that case was domicile. But the tribunal said it did not know what the advice would have been had the advice actually been taken since no one neither HMRC nor the taxpayer had reduced any evidence on that question and since the burden of proof was on HMRC in the absence of HMRC proving what a reasonably competent advisor would have advised the tribunal held that HMRC had failed to prove that the careless omission to take advice caused the loss of tax. So that was Strachan. Another case taking that strict approach to causation is Bella Figura in the upper tribunal in which the first tier tribunal had identified that the taxpayer had carelessly failed to take advice. So similar issue once again. But the upper tribunal overturned the decision saying if the further advice had been received then the advisor probably would have advised that the documentation in that case produced the result that the taxpayer wanted so the failure to take advice made no difference it did not cause the error.

So in that case the tribunal practically made a finding as to what the further advice would have actually been. So those are examples of cases in which the tribunals have applied a stricter approach to the causation condition. At the other end of the spectrum we have Atherton in which the upper tribunal placed reliance on section 118 subsection 5 of the taxes management act for those of you who do not go to bed reading your yellow books that says a loss of tax is brought about carelessly by a person if the person fails to take reasonable care to avoid bringing about the loss.

So it's a sort of deeming or defining provision that extends the circumstances in which the carelessness will be treated as bringing about the loss of tax. And in Atherton the omission was a failure to explain the specific entry in the tax return and the taxpayer argued that the omission had no bearing whatsoever on the loss of tax. The upper tribunal essentially said if you have failed to take reasonable care in avoiding bringing about the insufficiency that is enough to meet the condition. It's almost saying that the mere existence of carelessness means that the carelessness is treated as bringing about the loss of tax and is right on the verge of basically dispensing with the causation requirement at all.

So before Mainpay you had some cases applying a very strict approach to the causal link between carelessness and loss of tax and other cases almost saying that it's not a condition at all.

Okay so does Mainpay tell us the right approach to take? Does it reconcile those two approaches and tell us which one to follow?

Yes that is expressly what the upper tribunal and Mainpay was seeking to do because it set out the approach in Atherton and section 118 sub 5 and also the approach in Bela Figura and it sought to provide some general guidance on the issue of causal link. And what I think we can take from the decision is the following. Firstly there definitely is a burden on HMRC to establish that the careless behaviour has caused the loss of tax. So if Atherton was saying anything different then it was wrong and section 118 sub 5 does not remove the burden or the need for a connection between the carelessness and the loss of tax and that must be right because there must logically be some connection between the loss of tax and the carelessness.

Secondly it said that what HMRC need to do to satisfy the burden of proof is going to be fact specific but the burden is on HMRC to show what the taxpayer should have done differently as seems to have been stated in Bela Figura but that should not necessarily involve excessive detailed speculation or counterfactuals as to how the taxpayer might have responded for example to particular advice and I think if you look across the case law that is what has been worrying the tribunals. Having to engage in speculation as to what a taxpayer might have done which cannot be properly evidenced by either side. Applying those points in Mainpay the taxpayer had argued HMRC need to prove if advice had been taken the contracts relied upon would have been amended and would have been effective for tax purposes and the upper tribunal said this was a case where HMRC's burden did not stretch that far it was sufficient in that case to identify that further advice should have been taken and that it was possible that the advice would have been different.

So you told us when you're summarising what we can get from the decision that the burden of proof is I think you called it fact specific. Are we now in a position where we can identify the principles on carelessness and causation clearly and then take that fact specific exercise on following Mainpay?

I'd love to say that it's now all lovely and clear and I think notwithstanding the best intentions of the upper tribunal wherever you have a test which is stated to be fact specific there's going to be left uncertainty. We know there needs to be a counterfactual and it's HMRC who need to prove, identify and then prove, that counterfactual to a certain extent but excessive speculation has been criticised.

So for example in a case where HMRC say the failure isn't a mission to take advice it may be sufficient for HMRC to prove that the advice might have been different or at least to put forward some form of evidence that it could have been. But they don't need to prove for example how the taxpayer might have reacted to that advice because the latter would be speculation. I'm going to put it out there because it is said to be so fact specific I think the issue of causation is going to be a very prominent feature of assessment and penalty litigation for a while until we get some really clear authority from the higher courts or we get some more trends or lines of cases which tell us how to apply the principles that have been identified.

Okay thanks Ben I think that's covered Mainpay so let's move on to another case this time we'll go for Go City.

Ben

Yes that's a very interesting case why don't you tell us what that case is about.

Yes so this is a case in the first tier tribunal the substance which we don't really need to look at at all is about VAT and vouchers but it is important that it's about VAT. I'm interested in one particular procedural point that comes out of that case and it's about two so-called protective assessments that HMRC had raised in respect to the VAT and whether or not those were valid assessments.

What was the precise validity procedural point that arose?

Well we all know that HMRC often raise protective assessments in both indirect and direct tax that isn't actually a defined term in the statute at all. All it really means is an assessment which which has been raised before HMRC have finished their inquiries or their investigations and they're doing it at least in part to protect themselves against time limits expiring. And so, what the tribunal was considering was whether or not HMRC had complied with the statutory requirements for a VAT assessment rather than considering whether a protective assessment was in broad terms a valid thing.

And those statutory requirements could you remind everyone what they are?

So what we were looking at here was section 73 of the value-added tax act. That gives power to assess where a taxpayer has submitted a return, but it appears to the commissioners that the return or returns were incomplete.

That's the statutory wording. In order to meet the requirement it seemed to be common ground as between HMRC and the taxpayer in the case, that the commissioners must have formed a view that the return was incorrect. So the question that we've then come to is whether or not the commissioners have formed a view in any particular case.

And that's interesting because already we can see parallels for those listeners who deal with direct tax with the discovery assessment provisions where it needs to be where an officer of HMRC needs to have discovered a loss of tax. So what did the tribunal decide here in a VAT context?

Yeah so they looked as you might expect at the assessment letters the letters that explained the detail of the assessments and those letters began with the officer saying the sort of phrase that we see repeated in most of these letters, that they believed that the taxpayer hadn't declared the correct amount of tax due. But those letters also went on to say that HMRC hadn't formed a final position and that this wasn't a fully considered decision.

So the letters show a bit of a mixed picture. They then also looked at the officer's oral witness evidence. Most importantly they looked at a technical advice request which the officer had sent to the relevant policy team and that request showed that HMRC had three possible analyses in mind and not all of those analyses would mean that tax was incorrect.

That request indicated which analysis HMRC preferred but the language showed that the officers hadn't decided which was the right position. They'd sent off that request, they hadn't received a response by the time they issued the assessments and ultimately in the witness evidence the officer accepted that the assessments had been issued because the time limit was due to expire. So that was the reason for the assessment rather than that the officer had come to a view and so because the officer hadn't come to a view the tribunal said the assessments were invalid.

And other than the tribunal actually siding with the taxpayer on a procedural issue why is that of general interest?

Well if you're advising a taxpayer and thinking about VAT in particular here, and you're challenging an assessment you will want to look closely at when the officer formed a view and whether the officer had formed a view by the time they issued an assessment and think about whether or not there's something here that you might want to ask about or challenge. That might involve asking HMRC to give you copies of their internal documents so the technical advice request is an example of that and it's just worth noting that the tribunal was willing to direct that here. So you might ask and you might get a no, but you might be able to apply to the tribunal to ask them to direct the disclosure of those documents.

That's VAT but this is also relevant for other taxes which use the same language so landfill tax is a good example of that. It's something to look out for.

And that would fit in nicely because generally the burden of proof in VAT in relation to time limits is on the taxpayer in particular relation to the one year time limit so it's not unusual for a taxpayer to make an application for specific disclosure to see HMRC's internal documents as to when they reached the relevant conclusion.

So I suppose what they might do is they might just extend the application they were thinking of making anyway to include this pseudo discovery when did you form the view and what was your view at the time.

Yes I think that's right. I mean the case doesn't tell us where the burden of proof lies and it didn't need to because there was enough evidence on the table for the tribunal to make the decision in this case.

So if you're acting for a taxpayer it's probably sensible to assume for now that the burden of proof lies on you on these issues and to raise the issue yourself. That doesn't mean we can't go on to have an argument later about whether that's right but for the moment be alive to the point and raise it yourself and ask for those documents.

Let's have the argument now.

So I was thinking about this because it came up in a case I was looking at yesterday. So in direct tax we have now a very well-known case called Burgess and Brimheath which has been applied a number of contexts which says that even if the taxpayer does not raise the issue of discovery or other validity requirements in relation to a direct tax assessment it is still for HMRC to plead and prove the validity of the assessments. Can taxpayers and will tribunals take the same approach in relation to VAT?

I think there's a real chance that they might. I think it's very hard to see how a taxpayer can prove when HMRC formed a view and so you must either end up in the situation where the burden of proof is on HMRC or you as a taxpayer have to be able to get hold of those documents. I mean, as you're saying it's the same the one-year time limit point of view. But I certainly think there's an argument, a good argument, that you could say the burden of proof is on HMRC for this sort of point.

Now mainly in discovery, direct tax cases with discovery, that really just involves putting it in the pleadings and then ideally seeing if there is a dispute about it so that everyone knows that dispute is there to start with. But we know and Burgess and Brimheath is obviously the prime example, that sometimes it comes out much later.

The peculiarity is though that of course in direct tax the burden of proof on time limits and validity definitely rests with HMRC. That's well established, been established for a very, very long time whether it's right or wrong. In VAT it's equally well established that the time limit issue, the burden is on the taxpayer which is odd, because it means that even though the have all of the information at their disposal, the taxpayer needs to often ask for disclosure of the way the revenue reached their decision and the timing of that decision, for example, as well. So if the burden is already on the taxpayer in relation to time limits, I suppose the question the tribunal might ask itself is why would it be different in relation to this issue?

Yeah, I can see that. There aren't pleas in the legislation. So it might be that that context wins out that that's where the burden of proof sits generally here and so that's where it's going to sit in all aspects other than obviously when we're talking about deliberate behavioural carelessness. We're going to have to wait and see but in the meantime, protect yourself by raising the point or asking the question.

It might not be obvious that there is an issue but think about it in the same way that you think about best judgment in a VAT assessment. Raise the topic of best judgment because people succeed on these challenges.

They do indeed. I agree to finish off this topic. I do agree it's slightly bizarre that you might have the taxpayer having the burden of proof in relation to whether or not the relevant revenue officer formed the requisite view but that does seem consistent. Perhaps that's no more strange than the taxpayer having to prove that there's been more than 12 months between the revenue reaching their conclusion and issuing the assessment. So we will see. I look forward to the first case on that. One more general question on this topic before we move on. Do you think HMRC can still issue protective assessments in a VAT context?

Yes, absolutely. Remembering that that isn't a statutory term, they can certainly issue a VAT assessment while they're still asking questions and considering things but they do need to have formed a view that the return is incomplete. They might have different approaches to that but they need to have formed a view one way or another that the return is incomplete.

Now, one might expect that HMRC would tighten up training on officers in how they express their views and how they note down their views in internal records, etc. etc. That might minimise the number of situations where this goes wrong but we know from Discovery and other cases that it does go wrong even with that sort of training or even with well-established principles.

Yes, I suppose the Tribunal would think it's not asking much to require HMRC to form a view even if potentially it's quite a tentative view and it's subject to internal checks and specialist advice, etc, and obviously subject to what the Tribunal have to say as well.

It's not asking much given that if a taxpayer does not appeal that decision it could result in a significant debt being incurred by the business.

Yeah, absolutely. I agree.

So now I think we're going to take a look at the Upper Tribunal decision in Outram.

Yes, so I think we're moving away from VAT assessments and back to the world of direct tax here, aren't we? Tell us what the issue is in Outram that you thought was interesting. We are moving away certainly because the issue here in Outram, it's an Upper Tribunal decision and it's actually looking at discovery assessments which are direct tax.

But the issue I thought was interesting for the purpose of this podcast was the question of whether the loss of tax had been brought about deliberately by the taxpayers. And VAT is equally applicable in indirect tax or direct tax context because the statute uses the same term of deliberate. And this case, Outram, is the latest in an ongoing development and clarification of the law in this area in relation to the concept of deliberate behaviour, which allows HMRC to issue assessments within extended time limits and also, of course, gives them the right to issue the highest penalties. And you've also got the deliberate defaulters regime, for example, where HMRC can publish taxpayer details as well.

Okay, so we're focusing on deliberate now. That's a term we've seen, as you say, in legislation across tax for many years. Do we already know something about it?

Yes, you'd think we would. Until 2010, tax legislation used the term fraudulent, but that was exchanged for deliberate. And since then, there's been a certain lack of clarity as to what Parliament actually intended when it changed the word from fraudulent to deliberate in the various statutory regimes.

That was most starkly seen in the Tooth case a few years ago, in which, in summary, a taxpayer knowingly put the wrong figure in a box in their tax return. But they did so only because there had been a software issue and they were told to explain to HMRC why they had put the figure in that particular box because they couldn't put it in the right box and they made a white space disclosure. But the Court of Appeal, even in those circumstances, they said that was deliberate, effectively in the sense that the inaccuracy had been included consciously.

I mean, it had been an accident they'd put that figure in the box. And I think many tax professionals struggled with that because if that was deliberate, then it felt like the definition would be very, very wide indeed. But the Supreme Court in two, thankfully, overturned that and stated that bringing about a loss deliberately means with an intention to mislead the revenue on the part of the taxpayer as to the truth of the relevant statement.

So the court held it wasn't enough for the inaccuracy to be conscious. It had to be with an intention to mislead. And that wasn't the case in Tooth because the taxpayer had explained what they were doing and why.

So does that mean we're coming close to that word fraudulent again? We've implied the same intention to mislead, dishonesty perhaps, and we're closer to that than we were in the Court of Appeal?

We're certainly closer to fraudulent than we are to conscious. And I think the connotations of fraudulent have been brought in essentially. You certainly need some element of misleading.

There's no strict element of deception, but misleading comes pretty close to that as well.

Yeah, intentional.

Indeed. I should add though, the Supreme Court in almost a sort of throwaway sentence also said that maybe recklessness would be sufficient in order to establish deliberate as well.

Okay. And what is recklessness? Tell us that first.

Okay. So recklessness encompasses the idea of acting unreasonably or taking an unreasonable risk. I mean, it's a phrase which at law school you'd most often hear in a criminal context because there are many crimes where the requisite state of mind is recklessness.

But, because deliberate is a subjective test, that's now well established, it doesn't matter whether the taxpayer acted unreasonably in an objective sense. For deliberate, there needs to be knowledge by the taxpayer of the inaccuracy and the intention to mislead. That is the critical difference between careless and deliberate. It's the subjective element.

Okay. So where does that leave us on recklessness? Is that enough for deliberate conduct or is that not enough of an intention?

I think where we've reached is that recklessness in an objective sense is certainly not enough. But what the tribunals have done is they've recognised that a taxpayer can act deliberately where they suspect that a document contains inaccuracies, that is a subjective element, and then they deliberately do not check. It's sometimes referred to as blind eye or Nelsonian knowledge of the inaccuracy. That's a reference to the story of Lord Nelson at the Battle of Copenhagen, realising he was being signalled to retreat and he put his telescope to his blind eye and said he could not see any signals.

So that's been recognised in the upper tribunal in cases such as CPR commercials, for example. So if a taxpayer suspects an inaccuracy and then makes a conscious decision not to check the correct position, that should constitute deliberate conduct. But obviously HMRC need to prove that the taxpayer had at least a suspicion.

So there's still a subjective element.

How are they going to do that? That sounds very difficult, doesn't it? Proving that someone had a suspicion. I mean, you might have documents or emails, I suppose. Other than that, it's pretty difficult.

Well, no more difficult, I suppose, than showing knowledge. And I think as ever, the tribunal is entitled to make findings as to subjective knowledge or suspicion by reference to the objective circumstances.

And I think what the tribunal has really done there is they feel that that's necessary. Otherwise, it seems to be you might have taxpayers who just don't check their returns, or they know there's something in the return and they say, well, actually, I didn't know it was wrong because I didn't check and I didn't ask anyone. And the tribunal isn't willing to sanction that sort of approach to compliance.

Okay, so you might be looking at things like how sophisticated the taxpayer is in as part of the context.

You would look at that, you would look at their knowledge. I mean, I think the most likely circumstance in which this is going to arise is where there's a factual situation.

For example, if you know about certain income, and you're wondering whether or not it should be included. If you simply don't tell your advisor, or you don't check whether, for example, it's been included in your tax return, even though it's been included, you would still be treated as having acted deliberately, because you must have a suspicion that there's inaccuracy in your tax return. And what you're doing is you're deliberately choosing not to check.

Okay. So, is Outram important? Do we need to pay particular attention?

Outram is sort of important because it's the latest case in a series of cases developing and refining the principles on deliberate conduct. But what it shows is that even though we've got to a position where we think we all agree on how to articulate the test, we still have some problems in particular applying it.

So, Outram is about one of the pendulum schemes, and the taxpayers claimed losses from trading in options, and it was a marketed tax avoidance scheme. And what the tribunal found was that the taxpayers knew it was a tax avoidance scheme. And then the tribunal also went on to say that they knew the scheme involved needing to have a trade.

And by the time of the appeal, it was accepted that in fact, the participants in the scheme were not trading as a matter of fact in law. But what the tribunal seems to have done is it put those points together, and it seems to have found that the taxpayers had acted deliberately. It was common ground that the first day had correctly identified the tests for deliberate conduct. There was references to Tooth, and there was also reference to the test in a case called Auxilium as well, i.e. it was necessary for the taxpayers not just to not have been trading, but to have knowingly provided HMRC with a document that contains inaccuracy. What the upper tribunal said when it looked back at the first year decisions allowed the appeal, because it said, even though the first tier appears to have identified the correct test, what it seems to have done is to apply its own conclusion that objectively the scheme did not work because there was no trade. And of course, what the first year should have done is applying a subjective approach, as it should have made specific findings as to the subjective knowledge of the taxpayers as to whether or not they were trading. That was the difference.

Okay, so did they need to know at the time, they knew at the time they weren't trading, presumably, is that?

No, what they knew at the time, no, they knew at the time that they needed to be trading.

Right, okay.

So they knew it was a tax avoidance scheme. To put it another way, in order for the conduct to be deliberate, it is not enough to be wrong, or even very wrong, you need to know you're wrong, at the time you submit your document. So that's the difference.

In that case, the taxpayers knew what needed to be shown. And then the tribunal found that actually their view was wrong. But there was no finding that they knew they were wrong.

That was the difference. It just, well, in fairness, the first it just wasn't clear exactly how they'd reached that conclusion. So the appeal was allowed, it's actually been remitted back to the first tier to make further findings as to whether the taxpayers knew the scheme did not work.

And what the Outram case shows is that even now, after X number of years of having this term ‘deliberate’ in the statutory code, and where we seem to have even reached a consensus on how to articulate the various principles for deliberate conduct, there are still significant difficulties in applying that test. And I think this explains why you may have the same as well, when you're doing investigations, and even when you're doing litigation as well. So regularly, we see disputes between taxpayers and HMRC about deliberate conduct, because it's very, it's a very difficult test to apply. And of course, it's a very important one, because it can in particular, change your assessment time limit from four years, six years, right up to 20 years, or even further.

Difficult to apply, because the factual situations are so varied, maybe also because the evidence can be tricky, because it's generally what's in one's mind. Are there other reasons why it's difficult to apply?

I think the point that I've seen in particular, is that what the revenues sometimes confuse is that they see taxpayers taking very aggressive positions in their tax return, or sometimes they see them being uncooperative during the inquiry, i.e. long after they've adopted, they've put whatever they need to in their tax return.

And they say, ah, look there, you are consciously trying to hold information back, or you haven't provided us all the answers. But that's not the question. The question has to be asked in terms of subjective view at the time the tax return is actually put in.

And I think that's one of the reasons HMRC get confused. Also, sometimes they've just been dealing with a taxpayer who maybe has done tax avoidance, and they think that it's very wrong tax avoidance, and it's unreasonable, but of course that does not equate to having a subjective belief, particularly in a complicated scheme or a complicated tax transaction, that actually, you knew that you were understating your tax liability.

So thank you very much, Ben, for telling us about Outram. This is obviously an area, assessments, deliberate carelessness, all of these things are areas where we'll be having lots more developments in the case law. So no doubt we will be back to talk about them again. Indeed, as we were discussing this podcast, there's been a new decision released by the Tribunal on burden of proof and assessments in the case of Sintra.

So that one's worth having a look at. And maybe we'll talk about it on a future podcast.

Thank you very much for listening to Pump Court Tax Chat.

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