A review letter from HMRC cancels discovery assessment, writes Nicole Kostic (RPC).
Adam Craggs and Robert Waterson (RPC) examine Sanderson, the latest discovery case in which the courts have attributed to the ‘hypothetical officer’ very little knowledge, notwithstanding extensive information having been made available to HMRC.
Adam Craggs and Robert Waterson (RPC) consider discovery assessments and the Upper Tribunal’s recent decision in Burgess and Brimheath Developments Ltd v HMRC.
The law and practice on discovery assessments has lost its balance and, along with it, any realistic protection for the taxpayer, writes Peter Vaines.
Tori Magill (Pinsent Masons) answers a query on the validity of a discovery assessment received by a taxpayer who participated in a marketed tax avoidance scheme.
Adam Craggs and Nigel Brook review Michael Freeman, a recent tribunal decision on when HMRC can raise a discovery assessment under TMA 1970 s 29