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