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DISCOVERY-ASSESSMENTS


Edward Reed and Pippa Goodfellow (Macfarlanes) provide this month’s review of private client developments that matter.

HMRC can’t wait forever to make a discovery assessment.

Card image Leyla Garahan Ben Webster James Drake-Linney
Ben Webster, James Drake-Linney and Leyla Garahan (Macfarlanes) consider the change in approach to limitation periods for overpayment claims and the practical issues that claimants are now likely to encounter.
Card image Sophie Lloyd Laura Jackson Hannah Manning

Hannah Manning, Sophie Lloyd and Laura Jackson (Travers Smith) consider how HMRC may use its new legislative power to automate certain functions.

A 20 questions guide, by Adam Craggs and Constantine Christofi (RPC).
A recent Upper Tribunal decision provides a useful refresher of the steps that can be taken to reduce the possibility of HMRC successfully making a discovery, writes Helen Adams (BDO).
Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
The judgment in Tooth increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.
Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.
The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May). 
 
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