Discovery Assessments 3rd Edition

This volume by Keith Gordon is still, we believe, the only book on the market that focuses exclusively on the topic of discovery assessments. 

Self-assessment was meant to bring greater finality to taxpayers’ affairs, but cutbacks at HMRC mean that fewer enquiries are being pursued. Consequently, when errors are picked up, HMRC are increasingly relying on their powers to make discovery assessments. Frequently, however, HMRC overlook (and often fail even to mention) the statutory safeguards that are intended to protect taxpayers from challenges outside a formal SA enquiry. It is only with a clear guide to the extent of HMRC’s powers that advisers can ensure that they protect their clients from inappropriate challenges.

The rules have been subject to considerable scrutiny, particularly in the past seven years, and the author of this title has been involved in many of the leading cases. His book provides tax advisers with a clear and comprehensive guide to the rules concerning discovery assessments and contains much practical advice explaining how such assessments may be challenged.

“An essential guide for any practitioner acting in cases involving discovery assessments, and is both scholarly and practical.” – TAXline review of first edition

Contents (in brief)

• Overview and introduction
• The meaning of “discover”
• Careless or deliberate conduct
• Insufficiency of disclosure
• Defences against a discovery assessment
• Time limits for discovery assessments
• Procedural matters
• Consequential claims by taxpayers
• Interaction with HMRC investigatory powers
• Appendices

New for this edition

• The Supreme Court Tooth decision (deliberate conduct, staleness).
• Updated commentary on “reasonable disclosure” (following Hicks and Beagles decisions).
• Interaction with standalone charges to income tax.
• Changes to discovery rules re Making Tax Digital.
• Higher level appeals (Upper Tribunal and beyond).

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