Rebecca Murray examines which party to an appeal in the First Tier Tribunal bears the burden of proof and what the standard of proof is, under the new time limits for discovery assessments
A taxpayer may be appealing to the First Tier Tribunal (Tax Chamber) ('the FTT') where inter alia:
● There has been an enquiry into the tax return for a particular year of assessment and a closure notice has been made by HMRC together with an amendment to the self-assessment return (TMA 1970 s 28A);
● An assessment has been made under TMA 1970 s 29 (a 'discovery assessment') on the basis that there was insufficient information made available to the Inspector during the time in which an enquiry could have been opened (or during an open enquiry) for him to realise that there was a situation...
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Rebecca Murray examines which party to an appeal in the First Tier Tribunal bears the burden of proof and what the standard of proof is, under the new time limits for discovery assessments
A taxpayer may be appealing to the First Tier Tribunal (Tax Chamber) ('the FTT') where inter alia:
● There has been an enquiry into the tax return for a particular year of assessment and a closure notice has been made by HMRC together with an amendment to the self-assessment return (TMA 1970 s 28A);
● An assessment has been made under TMA 1970 s 29 (a 'discovery assessment') on the basis that there was insufficient information made available to the Inspector during the time in which an enquiry could have been opened (or during an open enquiry) for him to realise that there was a situation...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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