Hartley Foster and Louisa Warburton review the impact of the Court of Appeal decision in Hankinson.
Historical background to ‘discovery assessments’Before the introduction of self-assessment the role of assessing was undertaken by the inspector rather than by the taxpayer. The taxpayer was required to complete a return disclosing his categories of income and chargeable gains but the return did not determine his legal liability to tax. If the inspector was satisfied by the return he would make an assessment in accordance with it (under TMA 1970 s 29(1)(a) as enacted); if not...
