Discovery assessments – where are we now?

Meg Wilson, tax writer at Croner-I, examines when HMRC can use discovery assessments, particularly in light of last month’s Supreme Court decision in R & C Commrs v Tooth [2021] BTC 15. It also highlights issues concerning discovery assessments that still require clarity

The article refers to the discovery assessment legislation as it applies to individuals for income tax and capital gains tax in Taxes Management Act 1970 (TMA 1970), section 29. However, similar discovery rules apply for other taxes, such as for corporation tax (Finance Act 1998 (FA 1998), Sch. 18, Pt. V), stamp duty land tax (FA 2003, Sch. 10, Pt. 5) and the annual tax on enveloped dwellings (FA 2013, Sch. 33, Pt. 5).

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