In J Hicks v HMRC [2018] UKFTT 22 (12 January 2018) the FTT found that discovery assessments were not valid.
HMRC had issued discovery assessments in relation to trading losses claimed by Mr Hicks which resulted from arrangements devised by Montpelier.
The first issue was whether there had been a discovery by HMRC. Mr Hicks contended that the discovery had become stale by the time the assessment was issued. The inspector’s involvement had begun in January 2014 when HMRC was gathering information on the scheme in relation to three representative members (who did not include Mr Hicks). However the assessment had only been issued in March 2015. The FTT found that the inspector had clearly ‘crossed the threshold’ of discovery in November 2014 when he had written to Mr Hicks informing him that he had concluded...
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In J Hicks v HMRC [2018] UKFTT 22 (12 January 2018) the FTT found that discovery assessments were not valid.
HMRC had issued discovery assessments in relation to trading losses claimed by Mr Hicks which resulted from arrangements devised by Montpelier.
The first issue was whether there had been a discovery by HMRC. Mr Hicks contended that the discovery had become stale by the time the assessment was issued. The inspector’s involvement had begun in January 2014 when HMRC was gathering information on the scheme in relation to three representative members (who did not include Mr Hicks). However the assessment had only been issued in March 2015. The FTT found that the inspector had clearly ‘crossed the threshold’ of discovery in November 2014 when he had written to Mr Hicks informing him that he had concluded...
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