In Dr S Rizvi v HMRC [2023] UKFTT 124 (TC) (13 February) the FTT held that the taxpayer’s agent had been careless when submitting a claim for enterprise investment scheme (EIS) relief for investments which had not been granted EIS3 certificates. HMRC was therefore entitled to raise discovery assessments.
The taxpayer Dr Rizvi had made a number of claims for EIS relief over several tax years ending in 2017. When those claims were made he did not hold an EIS3 (being a compliance certificate required before a claim for EIS relief can be made) in respect of those investments.
In early 2021 HMRC raised discovery assessments on Dr Rizvi in respect of those tax years.
Dr Rizvi accepted that he was not entitled to make the claims for EIS relief. The only issue before the FTT was whether Dr Rizvi or someone acting on his behalf ...