.png)
.png)
The requirements that must be met for a discovery assessment to be made by an HMRC officer.
KEY POINTS
- Are new attempts being made to curb HMRC’s enthusiasm for discovery assessments?
- TMA 1970 s 29 must balance the need to make further assessments and the taxpayer’s protection against indefinite liability.
- Is there an insufficiency that the officer could not have been aware of on the basis of the available information?
- Should the officer be expected to be aware of all the information that HMRC have?
- The officer must be assumed to have the level of knowledge and understanding that would reasonably be expected.
Even the most adroit tax advisers have clients who have done a spot of tax-planning of their own perhaps with the assistance of avoidance scheme promoters. Some are involved in structures devoid of legal or other merit. Contractors’ offshore loan...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
