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Discovery assessments
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Discovery assessments
DISCOVERY-ASSESSMENTS
Scatola: 20 years to raise s 75A discovery assessments
Sinisa Butina
Angela Savin
Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper
Tribunal’s reasoning in
Scatola
and the broader ramifications for taxpayers
seeking certainty and finality to their SDLT affairs.
R Madsen v HMRC
Invalid discovery assessment concerning failed SDLT scheme.
A Outram and another v HMRC
Discovery assessments out of time
Other cases that caught our eye: 27 February 2026
Discovery assessment in respect of travelling expenses: In F Uzoh v HMRC [2026] UKFTT 231 (TC) (5 February), an employee, who had not been within self-assessment, signed up with a repayment agent ‘Tommy’s Tax’, which then filed tax returns on his...
P Kearney v HMRC
Residency dispute and appeal against self-assessment penalties
J O’Neil and others v HMRC
Redress payment taxable as post-cessation receipt
Mainpay Ltd v HMRC
Court of Appeal rejects ‘third option’ for employment contracts, but confirms causal link to carelessness before assessment timeframe can be extended
G Stenhouse and another v HMRC
Partial wins for taxpayers in late appeal cases
B Zzaman v HMRC
FTT warning over the dangers of using AI
Other cases that caught our eye: 30 May 2025
No reasonable excuse for misunderstanding HMRC’s letter: If HMRC write to you saying that you no longer need to complete a self-assessment tax return what does that actually mean? The taxpayer in A Hussain v HMRC [2025] UKFTT 546 (TC) (19 May)...
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of
6
EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
Tax and the City for July 2026
When Ramsay does not rescue HMRC
BlueCrest: the impact for asset managers
Legislation Day 2026: The securities transfer tax