Business Investment Relief   Introduction   I decided to update this article as Business Investment Relief is something I have spoken to clients about quite a few times in recent 
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Raymond Tooth – Discovery Assessment is Invalid says Court of Appeal Background – Tooth v. HMRC In the case of Raymond Tooth v HMRC, Mr Tooth had participated in a 
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Staleness: When HMRC is Out of Time to Raise Discovery What is staleness? Firstly, it should be stated that this is very much a developing area of the law. As 
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Understanding Careless or Deliberate Behaviour & Discovery Assessments As we have seen from the article setting out the requirements for a discovery assessment to be validly raised, a valid discovery 
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General – How to Prevent a Discovery Assessment One of the requirements for their to be a discovery, absent any careless or deliberate behaviour by the taxpayer or agent, is 
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Change of View… When HMRC Launches a Discovery Assessment In order for them to make a discovery, it must be as a result of HMRC coming to a new conclusion 
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Discovery assessment HMRC – signpost   Introduction   Welcome to our Signpost relating to HMRC discovery assessments. This provides a link to a number of articles we have put together 
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EU Law & UK Tax – A ‘High Level’ Analysis Introduction This note is a ‘high level’ analysis of the impact of EU law on the UK tax system and 
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What is a remittance? Non-UK domiciled individuals have the ability to claim the remittance basis which means that their overseas income or gains are not subject to UK tax if 
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Code of Practice 9 (“COP9”) – Signpost   HMRC COP 9 cases Code of Practice 9 is only issued as part of the Contractual Disclosure Facility and is solely used by HMRC 
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