DISCOVERY-ASSESSMENTS

The judgment in Tooth increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.

Clara Boyd

Ian Robotham

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.

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).

Constantine Christofi

Robert Waterson

Even staler.

Helen Adams

Helen Adams (BDO) considers the extent of HMRC's powers on discovery in the light of recent case law.

Steven Porter

Josie Hills

Josie Hills and Steven Porter (Pinsent Masons) explore when a discovery by HMRC is considered stale following recent case law.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision.

Andrew Hubbard

A number of recent tribunal decisions have added to our understanding of how this important part of the tax system works, writes Andrew Hubbard (LexisNexis).

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.