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

17 October, 2019
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

The extra-territorial reach of HMRC’s investigatory powers

07 February, 2019
In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC, the Court of Appeal determined that HMRC had power to issue a compulsory information request to an individual outside the UK (for the purpose of checking that individual's tax position). Read more