A recent tribunal decision reaffirms that the white space is not a shortcut that allows tax agents to avoid the consequences of their negligence, explains Ben Webster (Macfarlanes).
The complexity of the modern tax code can leave tax agents unsure of how tocomplete their clients’ tax returns. A common approach is to file using the ‘best case’ scenario for clients but then include a separate disclosure to HMRC that explains the possible uncertainty. Such disclosures are known as ‘white space’ disclosures. The idea is that the filing position secures the best immediate tax result for clients while the white space disclosure protects them from the various downsides – penalties extended HMRC deadlines increased scrutiny – if the filing position is wrong.
However the First-tier Tribunal has reaffirmed in Johnson and Johnson v HMRC [2022] UKFTT 156 (TC) that such white space disclosures can...
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A recent tribunal decision reaffirms that the white space is not a shortcut that allows tax agents to avoid the consequences of their negligence, explains Ben Webster (Macfarlanes).
The complexity of the modern tax code can leave tax agents unsure of how tocomplete their clients’ tax returns. A common approach is to file using the ‘best case’ scenario for clients but then include a separate disclosure to HMRC that explains the possible uncertainty. Such disclosures are known as ‘white space’ disclosures. The idea is that the filing position secures the best immediate tax result for clients while the white space disclosure protects them from the various downsides – penalties extended HMRC deadlines increased scrutiny – if the filing position is wrong.
However the First-tier Tribunal has reaffirmed in Johnson and Johnson v HMRC [2022] UKFTT 156 (TC) that such white space disclosures can...
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