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Discovery assessments
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Discovery assessments
DISCOVERY-ASSESSMENTS
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
Other cases that caught our eye: 4 April 2025
Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...
Other cases that caught our eye: 14 June 2024
VAT on KFC sauce pots: Queenscourt Ltd v HMRC [2024] UKFTT 460 (TC) (3 June 2024) concerned whether a supply of a sauce pot with a takeaway meal in a Kentucky Fried Chicken franchise was part of a standard rated supply of hot food or a separate...
Other cases that caught our eye: 7 June 2024
Non-domiciles and remittance basis of taxation: In A Alimahomed v HMRC [2024] UKFTT 432 (TC) (23 May 2024), the FTT allowed part of the taxpayer’s appeal, finding that a discovery assessment in relation to the 2015/16 tax year was not valid...
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Other cases that caught our eye: 15 February 2024
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: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
How to handle transfer pricing discovery assessments
Joel Cooper
Paula Ruffell
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a
‘protective’ discovery assessment is issued for a transfer pricing matter.
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7
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
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
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GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
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Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
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Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
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The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer