Commentary

A6.707 Discovery—the restrictions on HMRC's power to issue discovery assessments

Administration and compliance

A6.707 Discovery—the restrictions on HMRC's power to issue discovery assessments

A6.707 Discovery—the restrictions on HMRC's power to issue discovery assessments

HMRC's powers to issue discovery assessments are not unfettered. There are important statutory protections built into the system. If a discovery assessment is to be successfully challenged it is likely to be by invoking one of these protections.

These protections are discussed in the following articles:

  1.  

    •     Prevailing practice (see A6.708)

  2.  

    •     Careless or deliberate behaviour (A6.709)

  3.  

    •     Available information and the 'hypothetical officer' (A6.710)

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