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Voyage of discovery

08 December 2015 / Derek Francis
Issue: 45230 / Categories: Comment & Analysis , Investigations

The requirements that must be met for a discovery assessment to be made by an HMRC officer.


  • 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...

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