HMRC issued the four discovery assessments to the appellant, James Fera, related to child benefit claims for five years from 2016 to 2020 when he was earning over £60,000, which exceed the £50,000 cap on claims.

The discovery assessments resulted in a high income child benefit charge (HICBC) of £4,056 under section 29 of the Taxes Management Act 1970. The case centred around whether Fera’s claim was made before a change in the law on demands for back payment.

Fera was employed throughout the period in question and his total salary, as well as his company car and bonuses, exceeded the amount while his wife, Angela Fera, claimed the child benefit.