Tag Archives: deliberate behaviour

Tooth Ache!

HM Revenue and Customs’ (HMRC’s) power to make discovery assessments is a formidable tool. The ordinary time limit for HMRC to make income tax or capital gains tax discovery assessments is four years after the end of the relevant tax year. However, a 20-year extended time limit applies in cases of ‘deliberate behaviour’ by taxpayers.… Read More »

Can ‘careless’ be as bad as ‘deliberate’?

Mistakes by taxpayers in tax returns are common but might go undetected until it is too late for HM Revenue and Customs (HMRC) to open an enquiry into the return within normal time limits. However, HMRC may make a discovery assessment outside the normal enquiry ‘window’ broadly if HMRC can demonstrate that the taxpayer’s mistake… Read More »