HMRC v Hicks clarifies the standard of work that the Upper Tribunal expects an agent to produce in order to escape being considered careless such that HMRC can use extended time limits to issue discovery assessments. It also refocuses attention on the quality and adequacy of a taxpayer’s disclosure in order to prevent discovery assessments being issued under TMA 1970 s 29(5) in the absence of culpable behaviour and enquiries. Consequently, it provides a useful refresher of the steps agents may take, in conjunction with clients, in order to reduce the possibility of HMRC successfully making a discovery.
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HMRC v Hicks clarifies the standard of work that the Upper Tribunal expects an agent to produce in order to escape being considered careless such that HMRC can use extended time limits to issue discovery assessments. It also refocuses attention on the quality and adequacy of a taxpayer’s disclosure in order to prevent discovery assessments being issued under TMA 1970 s 29(5) in the absence of culpable behaviour and enquiries. Consequently, it provides a useful refresher of the steps agents may take, in conjunction with clients, in order to reduce the possibility of HMRC successfully making a discovery.
If you are not a subscriber, subscribe now to read this content.
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