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Comments made by Court of Appeal judges in a recent case relating to 'discovery' assessments have potentially made it harder to obtain certainty that HMRC cannot go back and challenge a tax return, by raising issues around what constitutes a ‘deliberate’ error by the taxpayer, according to Pinsent Masons.
The law firm acted for Raymond Tooth in a Court of Appeal hearing on two issues related to his participation in the Romangate tax avoidance scheme which was designed to utilise employment-related losses incurred in 2008/09 to relieve his liability to tax on other income.
Read more at Accountancy Daily.