Time-barred assessment win

The case of St Martins Medical Services Limited (TC2162) is a recommended read for those seeking the excitement of a trenchantly expressed ruling, and the twists and turns of an HMRC in some turmoil over their own error of timing.

At the heart of the case was the fact that HMRC’s assessment (for more than £1m) had been ruled out of time in a previous tribunal decision. But, undaunted, HMRC believed it saw circumstances where it could succeed by following a new path and litigating once more. It failed, spectacularly.