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Taxpayer Rights & Rule of Law

Raymond Tooth – Discovery Assessment Invalid says Court of Appeal

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 

Staleness: HMRC Out of Time to Raise Discovery

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 

Careless & Deliberate Behaviour – Discovery Assessments

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 

How to Prevent a Discovery Assessment – the Facts

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 

When Can HMRC Make a Discovery Assessment?

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 

Discovery Assessment HMRC – Signpost

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 

What is a Remittance?

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 

Private Sector IR35 & Off Payroll Working – Tax & April 2020

IR35 & THE PRIVATE SECTOR It has been announced that the IR35 provisions relating to the public sector will be introduced into the private sector. The proposal is subject to 

Professional Negligence & Tax Advice

In recent years, HMRC has made no secret of its stepping up efforts to increase the amount of tax revenue which it generates. The latest edition of its annual report, 

Tax Disputes with HMRC

Tax Disputes with HMRC In this article we take a look at how to progress matters when discussions with the inspector appear to have broken down or reached an impasse.