The decision was released in January 2018, four months after the case began and is 37 pages long.
The case was complicated covering many things, primarily:
The outcome was a victory with the appeal being allowed thereby invalidating HMRC’s discovery assessments.
The case is important to the tax world generally as it contains numerous points of principle. Key issues decided in our client’s favour and which are of wider interest generally are outlined below.
The case highlights how important it is to seek advice from a professional with an excellent knowledge of the relevant legislation, HMRC’s powers, taxpayer rights and safeguards.
If you would like to discuss this or any case involving discovery assessments or penalties, please call John Cassidy on 020 7842 7356 or Sean Wakeman on 020 7842 7285.