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Discovery and all that

04 August 2015 / Ray McCann
Issue: 4512 / Categories: Comment & Analysis , Policy
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The interaction between discovery, time limits and DOTAS
 
KEY POINTS
  • HMRC’s efforts to recoup back taxes are increasing.
  • There are strong statutory protections intended to give taxpayers certainty.
  • HMRC may assert careless or deliberate behaviour where time limits are involved.
  • Discovery may in effect be no more than a suspicion on HMRC’s part.
HMRC have ramped up their attack on tax avoidance and taken a keener interest in the filing positions of high net worth individuals and large corporates. As a result a detailed knowledge of when the department can pursue a past liability or make an “assessment where a loss of tax is discovered” has become a must-have skill for advisers. Knowledge of those provisions is not enough however because often HMRC are pursuing unpaid tax relating to years of assessment long since...

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