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View from the past
Key points
- Discovery assessments and their ability to go stale.
- It was not relevant that an arrangement did not intentionally involve avoidance.
- Deduction of input VAT without VAT invoices.
- The single or multiple supplies debate rumbles on.
- Confidence in HMRC’s alternative dispute resolution process after the First-tier Tribunal decision in The Serpentine Trust.
Last year was an important one in terms of the tax cases that appeared before the courts and tribunals. In this article I reflect on some of the key cases of 2018 as well as looking ahead to upcoming litigation that could be finalised by the end of 2019 – or soon after.
Discovery assessments
Over the past ten years the courts have been considering the possibility of whether a discovery can become ‘stale’ – when HMRC has taken too long to issue a discovery assessment so that it is invalidated.
In CRC v R Tooth [2018] STC 824 HMRC argued that...
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