The following Corporation Tax guidance note by Tolley provides comprehensive and up to date tax information covering:
The issue of disclosure is a fundamental risk management consideration for both compliance and planning work. The reason for this is that where insufficient disclosure has been provided, HMRC are able to open an enquiry beyond the normal enquiry window on the grounds of ‘discovery’.
HMRC’s discovery provisions are in place so that a taxpayer who has made a full disclosure in their tax return can expect finality once the window for raising enquiries has passed.
The discovery legislation is contained within TMA 1970, s 29. A discovery assessment can only be made if one of the following two conditions is met:
The second condition relates to disclosure. In this respect information ‘made available’ is defined as being:
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