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A Journey of Discovery

Richard Clarke and Jennifer Knowlson of PricewaterhouseCoopers LLP's tax investigations practice review recent developments concerning HMRC's rights to assess closed years
Recent tax cases indicate that HMRC is keen to use its discovery powers to force the payment of tax for 'closed' years beyond the self-assessment enquiry time limits. It follows that clients particularly those who entered into any complex transactions need to be advised that attaining finality to their tax position for a particular year is becoming increasingly difficult.
Discovery and income tax self-assessment
When income tax self-assessment (ITSA) was introduced guidance on how the new system would work (Self assessment: The legal framework) was published by the Inland Revenue. The introductory paragraph stated:

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