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DISCOVERY-ASSESSMENTS


It is encouraging to see the FTT dealing robustly with situations where HMRC fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Application to be joined as a party: The APP Accounting Group Ltd v Uberdev Ltd and another [2024] UKFTT 100 (TC) (25 January) is a case management decision in which the FTT allowed an application for a third party (TAAG) to be added to an appeal as...
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a ‘protective’ discovery assessment is issued for a transfer pricing matter.
HMRC met burden of proof in making discovery assessments.
Two victories for HMRC over claims for SDLT relief and another couple of wins in relation to discovery assessments, are among the developments reviewed by Edward Reed and Hriday Munim (Macfarlanes). 
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.

Case law on discovery has continued to evolve after the Supreme Court’s judgment in Tooth, as Helen Adams (BDO) explains.

A couple of further victories for HMRC on SDLT and a couple of victories for the taxpayer regarding information notices are among the developments reviewed by Edward Reed and Alice Mason (Macfarlanes). 
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