.png)
.png)
Computer says no
Key points
- The taxpayer reported a loss in the white space on his tax return because of a software limitation.
- The Court of Appeal ruled HMRC was unable to issue a discovery because it already knew of the tax insufficiency.
- The taxpayer had not acted deliberately because he did not intend to mislead anyone.
- But the inaccuracy was deliberate because the losses were reported in the wrong place.
- Deliberate has two meanings depending on the context in which it is used.
- For FA 2007 Sch 24 penalties deliberate usually requires blameworthy conduct.
We have all encountered situations in which the human beings on each side of a transaction agree on a sensible course of action but the computer software involved has either not anticipated the steps used or has been written in a way that blocks a desired step. This forces the human being into using a work-around to get the computer to...
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.
