.png)
.png)
Computer says no
Key points
- The taxpayer reported a loss in the white space on his tax return because of a software limitation.
- The Court of Appeal ruled HMRC was unable to issue a discovery because it already knew of the tax insufficiency.
- The taxpayer had not acted deliberately because he did not intend to mislead anyone.
- But the inaccuracy was deliberate because the losses were reported in the wrong place.
- Deliberate has two meanings depending on the context in which it is used.
- For FA 2007 Sch 24 penalties deliberate usually requires blameworthy conduct.
We have all encountered situations in which the human beings on each side of a transaction agree on a sensible course of action but the computer software involved has either not anticipated the steps used or has been written in a way that blocks a desired step. This forces the human being into using a work-around to get the computer to...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
