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AMAN BHARTI gives an inside view of the Charlton case
KEY POINTS
- Discovery cases under TMA 1970 s 29 have tended to go against the taxpayer.
- HMRC’s view after Langham v Veltema is now challenged by Lansdowne and Charlton.
- Discovery does not require any new facts to be revealed.
- The ‘notional HMRC officer’ can be expected to act as they would in the real world.
When self assessment was introduced in 1996 it was described as the most fundamental reform of the direct tax system since the introduction of PAYE in 1944.
Taxpayers were asked to take responsibility for completing their own tax returns and assessing their liability to tax which had previously been the...
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