If a contentious technical argument is likely to become a
central feature of a case, you should consider the implications
very carefully, preferably before you register it.
If the contentious point is not clearly covered by official
guidance, you must obtain advice from HMRC’s technical
experts (see
SCIG01690).
Although every case is different, you do not have a free hand
in developing technical arguments. You must ensure that the lines
you take are within the policy and interpretation followed by HMRC
as a whole.
It can be dangerous to use novel arguments without being
aware of the potential effect on other cases. An argument which
seems to work well in your own case could have unforeseen
consequences if it was applied throughout the department. Only the
technical specialists can see the whole picture, and only they are
in a position to evaluate novel arguments properly.
