Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
In my article ‘Go City: end of the road for ‘protective assessments’?’ (Bryn Reynolds) Tax Journal 27 September 2024 I commented on the challenges HMRC faced in Go City [2024] UKFTT 745 (TC) where they considered that they had issued a protective assessment. The First-tier Tribunal (FTT) in that case considered that what HMRC had issued was not a protective assessment at all. In another new case Jeffries & Sons v HMRC [2024] UKFTT 1031 (TC) HMRC did issue a ‘true’ protective assessment to the ultimate detriment of the taxpayer.
What is and is not a protective assessment?
The decision in Go City sets out that an assessment that is raised by HMRC purely to prevent an assessment from going out of time is not a protective...
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Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
In my article ‘Go City: end of the road for ‘protective assessments’?’ (Bryn Reynolds) Tax Journal 27 September 2024 I commented on the challenges HMRC faced in Go City [2024] UKFTT 745 (TC) where they considered that they had issued a protective assessment. The First-tier Tribunal (FTT) in that case considered that what HMRC had issued was not a protective assessment at all. In another new case Jeffries & Sons v HMRC [2024] UKFTT 1031 (TC) HMRC did issue a ‘true’ protective assessment to the ultimate detriment of the taxpayer.
What is and is not a protective assessment?
The decision in Go City sets out that an assessment that is raised by HMRC purely to prevent an assessment from going out of time is not a protective...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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