- FTT rules on validity of discovery assessments (GC Field & Sons Ltd v HMRC)
- Why it matters
- Case details
Tax analysis: In GC Field & Sons Ltd and others v HMRC, the First-tier Tax Tribunal (FTT) allowed the taxpayers’ appeal and found that discovery assessments issued in respect of stamp duty land tax (SDLT) avoidance arrangements were invalid. This was because HMRC had not discharged the burden of proving that either the taxpayers or their advisers had been negligent. The FTT’s decision includes consideration of the meaning of discovery, and the circumstances in which advisers should be regarded as acting ‘on behalf of’ a taxpayer for these purposes.
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