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DISCOVERY-ASSESSMENTS


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.
Mileage expenses: permanent workplace ‘consisting of London’
Unauthorised payments charge and surcharge: discovery assessment
Invalid discovery assessment concerning failed SDLT scheme.
Discovery assessments out of time
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...
Residency dispute and appeal against self-assessment penalties 
Redress payment taxable as post-cessation receipt 
Court of Appeal rejects ‘third option’ for employment contracts, but confirms causal link to carelessness before assessment timeframe can be extended
Partial wins for taxpayers in late appeal cases
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