HSF Trust Companies Survey – Tax Insights

We asked trust companies questions about the most significant risk and compliance issues they face. This blogpost, and accompanying podcast, consider the tax issues identified by respondents as most pressing. Read more

Discovery Assessments after Tooth: it’s never too late, it seems

Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years to 20 years.  In The Commissioners for HMRC v Raymond Tooth, the Court of Appeal held that for an inaccuracy to be "deliberate", there need not be any culpable conduct attributable to the taxpayer in question. Read more