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The interaction between discovery, time limits and DOTAS
KEY POINTS
- HMRC’s efforts to recoup back taxes are increasing.
- There are strong statutory protections intended to give taxpayers certainty.
- HMRC may assert careless or deliberate behaviour where time limits are involved.
- Discovery may in effect be no more than a suspicion on HMRC’s part.
HMRC have ramped up their attack on tax avoidance and taken a keener interest in the filing positions of high net worth individuals and large corporates. As a result a detailed knowledge of when the department can pursue a past liability or make an “assessment where a loss of tax is discovered” has become a must-have skill for advisers. Knowledge of those provisions is not enough however because often HMRC are pursuing unpaid tax relating to years of assessment long since...
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