My client participated in a tax avoidance scheme in 2008. I submitted his tax return for the year ended 5 April 2008 disclosing the scheme reference number in the relevant box of the return. I completed the ‘white space’ additional information using the wording recommended by the scheme promoters. HMRC did not enquire into the return. In 2011 HMRC challenged the scheme and opened enquiries into the 2009 and 2010 returns of some participants. My client joined the litigant group after receiving a discovery assessment in March 2014. The scheme promoter has appealed on behalf of all litigants. Is the assessment valid and will he get an accelerated payment notice?
HMRC seems to increasingly issue discovery assessments to the users of tax avoidance schemes where the...
