Oct 29, 2021 Are HMRC’s conclusions reasonable? By Paul Hardwick HMRC v Sukhdev Mattu [2021] UKUT 0245 (TCC) is a recent application by HMRC to apply a tax-related penalty on Mr Mattu for alleged...
Aug 20, 2021 More discoveries about discovery assessments By Pippa Goodfellow Edward Reed Rebutting HMRC’s desire to stretch section 29 TMA 1970 still further, the Upper Tier Tribunal (UTT) has recently held that HMRC cannot...
May 17, 2021 Pulling the Tooth out: no concept of staleness By Damiano Sogaro The decision by the United Kingdom Supreme Court in HMRC v Tooth published on Friday is notable for rejecting the existence of staleness...
Apr 29, 2021 Staleness takes the biscuit: HMRC can’t wait forever to make a discovery assessment By Damiano Sogaro So-called "discovery assessments" have featured in the UK tax system since at least 1803, but the concept continues to evolve.What is a...