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Contentious tax quarterly

Speed read
The Supreme Court’s much awaited judgment in Tooth on discovery assessments has rejected the concept of ‘staleness’, but confirmed that the test for ‘deliberate inaccuracy’ requires an intention to mislead HMRC. The recent case of Hoey concerns the issue when and where a taxpayer can rely upon a PAYE credit; the Upper Tribunal’s decision in that case effectively means that actual PAYE deductions are within the First-tier Tribunal’s jurisdiction but not deemed deductions. Meanwhile, HMRC appears to be taking a greater focus on crypto-trading and cryptocurrencies as their popularity grows, and we are aware that HMRC is actively engaged with exchanges seeking information about their customers.

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