J Hargreaves v HMRC

In J Hargreaves v HMRC [2019] UKFTT 244 (12 April 2019) the FTT found that a discovery had become stale by the time the assessment was issued.

Mr Hargreaves had been the majority shareholder in Matalan until May 1998 when Matalan had become listed. He had retained his own shareholding at that time. In March 2000 he submitted Form P85 to HMRC stating that he had left the UK that month. He then disposed of his shares in May 2000 and in his 2000/01 tax return he ticked Box 9.2 stating that he was not resident in the UK. HMRC did not open an enquiry but they issued a discovery assessment for £84 000 000 in January 2007.

Mr Hargreaves appealed the discovery assessment contending that the discovery had become stale by the time the assessment was issued.

The FTT referred to its recent decision in Beagles ([2018] UKUT...

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