Discovery assessments continue to provide tax headlines. This month, we look at two cases regarding the validity of discovery assessments: a win for HMRC in Martino in the wake of the Supreme Court’s decision on staleness, whilst the taxpayer wins in McCumiskey. In Lowe, the tribunal examined the meaning of ‘on his behalf’ in the context of allowable expenditure for CGT purposes. Finally, there is partial success for the taxpayers in two cases dealing with the validity of information notices: Wiseman is a reminder of the limits of legal professional privilege, and Hackmey demonstrates that objective reasonable belief, rather than mere subjective suspicion, is required for raising information notices.
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Discovery assessments continue to provide tax headlines. This month, we look at two cases regarding the validity of discovery assessments: a win for HMRC in Martino in the wake of the Supreme Court’s decision on staleness, whilst the taxpayer wins in McCumiskey. In Lowe, the tribunal examined the meaning of ‘on his behalf’ in the context of allowable expenditure for CGT purposes. Finally, there is partial success for the taxpayers in two cases dealing with the validity of information notices: Wiseman is a reminder of the limits of legal professional privilege, and Hackmey demonstrates that objective reasonable belief, rather than mere subjective suspicion, is required for raising information notices.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
