Self-assessment was meant to bring greater finality to taxpayers’ affairs, but cutbacks at HMRC mean that fewer enquiries are being pursued. Consequently, when errors are picked up, HMRC are increasingly relying on their powers to make discovery assessments.
Frequently, however, HMRC overlook (and often fail even to mention) the statutory safeguards that are intended to protect taxpayers from challenges outside a formal SA enquiry. It is only with a clear guide as to the extent of HMRC’s powers that advisers can ensure that they protect their clients from inappropriate challenges.
The rules have been subject to considerable scrutiny, particularly in the past seven years, and the author of this title has been involved in many of the leading cases. His book provides tax advisers with a clear and comprehensive guide to the rules concerning discovery assessments and contains much practical advice explaining how such assessments may be challenged.
This is the only book on the market that focuses exclusively on the topic of discovery assessments.
“This is an essential guide for any practitioner acting in cases involving discovery assessments, and is both scholarly and practical.” – TAXline review of first edition
Keith Gordon MA (Oxon), FCA, CTA (Fellow), Barrister practises from Temple Tax Chambers in London.
New for this edition:
- the extended time limits for offshore-related matters;
- analysis of the decision in Anderson summarising the key ingredients of a discovery assessment;
- case law concerning staleness of assessments;
- the meaning of “deliberate conduct”;
- case law concerning section 29(5) (Hicks);
- other case law and legislative developments concerning the validity of discovery assessments.