Commentary

V7.325 Best judgement and unjust enrichment—planning points to consider

Part V7 Tax planning
Part V7 Tax planning | Commentary

V7.325 Best judgement and unjust enrichment—planning points to consider

Part V7 Tax planning | Commentary

V7.325 Best judgement and unjust enrichment—planning points to consider

The following planning points should be given consideration.

  1.  

    •     Always consider the credibility of a client's explanations regarding any best judgement assessment – how would the explanations appear in the eyes of an HMRC officer? And, more importantly, would they appear sensible reasons to an independent tribunal?

  2.  

    •     For best judgement assessments based on outputs calculations, there are many reasons for discrepancies – advisers needs to explore issues such as stock losses, wastage, discounted sales, own consumption, theft, breakages, seasonal variations. In reality, any challenge to an assessment needs to be

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