HMRC: Discovery assessment and staleness

 There is always much to discuss when it comes to HMRC, and one of the most topical areas is discovery assessments and staleness – a recent Supreme Court decision has impacted how this concept will be dealt with in relation to tax assessments in future. There are several other aspects that must be considered when appealing a discovery assessment including the burden of proof, behaviours and time limits. Even though there is now a definitive decision on staleness it does not mean we can no longer appeal older discovery assessments; it is a complex jigsaw with much to think about when looking to mount an appeal. Listen now to hear thoughts from our experts.