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Analysis by ADAM CRAGGS of the Upper Tribunal decision against the Revenue in the case of Charlton
KEY POINTS
- Conditions for discovery assessments.
- Information in the white space of the tax return.
- Significance of an SRN.
- Taxpayer may hold an opposing view from HMRC.
As readers will be aware HMRC can raise what are commonly known as discovery assessments outside the usual 12-month enquiry window under TMA 1970 s 29.
Whether they are entitled to raise a discovery assessment is an important issue for many taxpayers and their advisers as HMRC appear to be more prepared than ever to use their discovery powers to raise assessments outside the normal time limits.
Since the lead discovery case of Langham v Veltema [2004] STC 544 CRC v Lansdowne Partners Ltd [2011] EWCA Civ 1578 White v HMRC [2012] UKFTT 58 (TC) and William Blumenthal (TC2174) have all followed. The...
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