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17 October 2019
Discovery Assessments after Tooth: it's never too late, it seems
Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years …
07 February 2019
The extra-territorial reach of HMRC's investigatory powers
In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC ("Jimenez"),1 the Court of Appeal determined that HMRC had …
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