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The taxpayer was the beneficiary of loans from a trust. No interest was payable on the loans and this gave rise to a taxable benefit. However this was mistakenly not included in the taxpayer’s returns.
In December 2018 the taxpayer disclosed the tax due for the years 2014-15 to 2016-17 under the worldwide disclosure facility. After an enquiry it transpired that tax was also due for 2013-14. In March 2021 HMRC raised discovery assessments for all the years in question.
The taxpayer appealed.
Under the standard time limits HMRC would have four years from the end of the tax year to raise the assessments. The ‘requirement to correct’ rules for offshore income (F(No 2)A 2017 Sch 18 para 26) extended the assessing periods to 4 April 2021.
The taxpayer argued that the extended deadline was in effect superseded when new time limits for loss of tax involving...
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