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Discovery assessments
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Discovery assessments
DISCOVERY-ASSESSMENTS
How to handle tax appeals
Constantine Christofi
Adam Craggs
A 20 questions guide, by Adam Craggs and Constantine Christofi
(RPC).
Hicks, discovery assessments and careless advisers
Helen Adams
A recent Upper Tribunal decision provides a useful refresher of the steps that can be taken to reduce the possibility of HMRC successfully making a discovery, writes Helen Adams (BDO).
Private client review for October 2019
Andrew Goldstone
Stuart Adams
Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
'Staleness' and discovery: where are we now following the judgment in Tooth?
Natalie Martin
The judgment in
Tooth
increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.
Discovery assessments: the Court of Appeal in Tooth
Ian Robotham
Clara Boyd
Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.
Time limit traps: lessons from the 2019 loan charge
Richard Jeens
Rose Swaffield
The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May).
Hargreaves: 'staleness' and discovery assessments
Constantine Christofi
Robert Waterson
Even staler.
Atherton: challenging a discovery assessment
Helen Adams
Helen Adams (BDO) considers the extent of HMRC's powers on discovery in the light of recent case law.
Beagles: ‘staleness’ in discovery
Josie Hills
Steven Porter
Josie Hills and Steven Porter (Pinsent Masons) explore when a discovery by HMRC is considered stale following recent case law.
Addo: disclosure in tax appeals
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision.
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of
6
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
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HMRC manual changes: 5 September 2025
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
Submitting RIF notifications to HMRC
HMRC guidelines on declarations of accuracy and completeness
EV charging added to advisory fuel rates
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Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
Clear Pay Payroll Ltd v HMRC
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IN BRIEF
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Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
CenTax recommends changes to protect family farms
Soft Drinks Industry Levy credit repayments
Self’s assessment: Time for a wealth tax?
Highlights from HMRC’s 2024/25 annual report
MOST READ
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First failure to prevent the facilitation of tax evasion case
T Masters v HMRC
Government mulls reforms to property taxes
Government mulls reforms to property taxes
United Carpets (Franchisor) Ltd v HMRC