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01 September 2015
Correspondence from readers on topical subjects.
Another discovery
In my article “Discovery and all that” (Taxation 6 August 2015) I highlighted the interaction between “discovery” assessing time limits and culpability. It has been pointed out that I did not include any comment in relation to late assessments where the taxpayer has failed to notify chargeability to income tax so on. I hope the following will put that right.
So far as income tax and capital gains tax is concerned a taxpayer has an obligation to give notice of chargeability to tax (TMA 1970 s 7 with similar provisions for other taxes).
A taxpayer who fails to do so is liable to a penalty and extended time limits unless he had a reasonable excuse and any required notice was given without unreasonable...
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