Market leading insight for tax experts
View online issue

Discovery assessments: the Court of Appeal in Tooth

Speed read
The Court of Appeal decision in Tooth concerning discovery assessments has been eagerly awaited. The taxpayer disclosed in his online return the use of a scheme to generate employment losses, but a software glitch meant the disclosure could not be put in the employment tax section and was instead made in the partnership pages. HMRC issued a discovery assessment claiming it had made a discovery and that the return contained a deliberate inaccuracy. Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers in relation to what constitutes an inaccuracy in a return and what amounts to deliberate behaviour.

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:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top