Jim Wilson reviews HMRC's approach to raising 'protective' discovery assessments in light of a number of recent cases
From 1 April 2010 HMRC's window of opportunity for raising 'discovery assessments' has been significantly reduced. Finance Act 2008 restricted the general time limit for making claims and assessments from six years to four and therefore on 31 March 2010 overnight two years (and in cases of 'carelessness' up to 15 years) immediately became time barred for further assessment.
Prior to coming into force these changes received a great deal of attention within HMRC. Inspectors were asked to review their portfolio of cases and ongoing enquiries in order to consider whether or not discovery assessments should be raised for earlier years before they became time barred post 31 March 2010.
Unsurprisingly this led to a significant number of discovery assessments being issued by HMRC...
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Jim Wilson reviews HMRC's approach to raising 'protective' discovery assessments in light of a number of recent cases
From 1 April 2010 HMRC's window of opportunity for raising 'discovery assessments' has been significantly reduced. Finance Act 2008 restricted the general time limit for making claims and assessments from six years to four and therefore on 31 March 2010 overnight two years (and in cases of 'carelessness' up to 15 years) immediately became time barred for further assessment.
Prior to coming into force these changes received a great deal of attention within HMRC. Inspectors were asked to review their portfolio of cases and ongoing enquiries in order to consider whether or not discovery assessments should be raised for earlier years before they became time barred post 31 March 2010.
Unsurprisingly this led to a significant number of discovery assessments being issued by HMRC...
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:
