Non-domiciles and remittance basis of taxation: In A Alimahomed v HMRC [2024] UKFTT 432 (TC) (23 May 2024) the FTT allowed part of the taxpayer’s appeal finding that a discovery assessment in relation to the 2015/16 tax year was not valid because the issue of deliberate omission (under one limb of TMA 1970 s 29(4)) was not substantiated by HMRC. The FTT further found that it was insufficient for HMRC to simply say that the pleadings may have been over-prescribed in an attempt to depart from the original case pleaded in the absence of any application to amend the pleadings.
90a1d87b-c1b5-43c3-a720-cd324830adee.tmb-editorspic.jpg?sfvrsn=1b2d0a7e_1)
