Commentary

A6.701 HMRC's Discovery Powers—introduction

Administration and compliance

A6.701 HMRC's Discovery Powers—introduction

Division A6.7     Discovery

For updates affecting this Division please see Part A0 Updates

A6.701 HMRC's Discovery Powers—introduction

One of the key tests of any advanced tax system is the way in which it balances the interest of the state with the interest of individual taxpayers. Discovery is one of those difficult balancing areas: to what extent should taxpayers have certainty over their tax affairs when this conflicts with the state being able to recover tax which would otherwise be due?

Deliberate understatement

It is likely to be generally accepted that if somebody has put in a return which deliberately understates his or her income HMRC should have the power to investigate and assess any tax which has not been assessed. But equally there is likely to be agreement

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