Keith M Gordon Barrister takes a closer look at HMRC's power to raise discovery assessments and at the restrictions that might apply in the corporation tax self-assessment rules
The introduction of self-assessment a decade or so ago fundamentally changed the role of taxpayers in generating tax assessments. In particular the principal responsibility for assessing the tax due now falls on the taxpayer with HMRC being given the duty to monitor compliance and to assess any tax that has been under-assessed.
One of the few advantages of the self-assessment régimes is that they were supposed to restrict HMRC's powers to raise discovery assessments. However a combination of HMRC practice and a couple of court decisions means that the restrictions are not always of much help to taxpayers.
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Keith M Gordon Barrister takes a closer look at HMRC's power to raise discovery assessments and at the restrictions that might apply in the corporation tax self-assessment rules
The introduction of self-assessment a decade or so ago fundamentally changed the role of taxpayers in generating tax assessments. In particular the principal responsibility for assessing the tax due now falls on the taxpayer with HMRC being given the duty to monitor compliance and to assess any tax that has been under-assessed.
One of the few advantages of the self-assessment régimes is that they were supposed to restrict HMRC's powers to raise discovery assessments. However a combination of HMRC practice and a couple of court decisions means that the restrictions are not always of much help to taxpayers.
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:
