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K Tutty v HMRC

In K Tutty v HMRC [2019] UKFTT 3 (31 December 2018) the FTT found that a discovery made following the use of an electronic standard information package (‘E-SIP’) was not stale.

Ms Tutty had implemented arrangements to avoid SDLT and HMRC had issued a discovery assessment under FA 2003 Sch 10 para 28. Ms Tutty contended that the assessment was not valid.

Her main argument was that the assessment issued in January 2016 was stale as the discovery had been made in May 2014 when her return had been selected for checking by an E-SIP. The FTT found however that only clerical checks were performed at that stage and that the only person who could made a discovery was the officer in charge of the review at a later stage.

The FTT also thought that the officer did make a discovery when reviewing the...

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