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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.
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)...
Realbuzz Group Ltd v HMRC
Discovery assessment invalid
Go to page
of
6
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress