Following the Supreme Court’s decision in Tooth, questions remained as to the type of knowledge a taxpayer must have when it comes to deliberate inaccuracies in documents. The Upper Tribunal, in CPR Commercials Ltd, recently provided further clarity and confirmed that ‘blind-eye’ knowledge of an inaccuracy would be sufficient. However, the issue of whether recklessness as to accuracy would be sufficient (a question expressly left open by the Supreme Court) has not been engaged with in the same manner, and there remains uncertainty in the area.
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Following the Supreme Court’s decision in Tooth, questions remained as to the type of knowledge a taxpayer must have when it comes to deliberate inaccuracies in documents. The Upper Tribunal, in CPR Commercials Ltd, recently provided further clarity and confirmed that ‘blind-eye’ knowledge of an inaccuracy would be sufficient. However, the issue of whether recklessness as to accuracy would be sufficient (a question expressly left open by the Supreme Court) has not been engaged with in the same manner, and there remains uncertainty in the area.
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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