A review letter from HMRC cancels discovery assessment, writes Nicole Kostic (RPC).
Adam Craggs and Robert Waterson (RPC) examine Sanderson, the latest discovery case in which the courts have attributed to the ‘hypothetical officer’ very little knowledge, notwithstanding extensive information having been made available to HMRC.
Adam Craggs and Robert Waterson (RPC) consider discovery assessments and the Upper Tribunal’s recent decision in Burgess and Brimheath Developments Ltd v HMRC.
The law and practice on discovery assessments has lost its balance and, along with it, any realistic protection for the taxpayer, writes Peter Vaines.