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Discovery assessments post-Hankinson

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Uncertainty remains as regards a number of aspects of HMRC's discovery powers. Hankinson concerned whether the condition that the inspector could not reasonably be expected, based on information that has been made available, to have been aware of the under-assessment constitutes a pre-condition that needs to be satisfied before a discovery assessment can be raised lawfully or is to be determined on appeal to the Tribunal. The Court of Appeal held that it was the latter. It is considered that that may not be the case as regards corporate taxpayers.

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