Rachel Ferrari successful in tax appeal
Rachel Ferrari acted for the taxpayer in an appeal concerning the tax treatment of a quarter of a million pounds received by the appellant over 10 years ago.
The appeal involved detailed argument as to the availability of HMRC’s power to issue a discovery assessment under s.29 Taxes Management Act 1970, including whether the taxpayer had acted ‘deliberately’ – i.e. intending to mislead HMRC – per CRC v Tooth [2021] UKSC 17.
The First-tier tribunal allowed the appeal in respect of both the discovery assessment and the related penalty assessment.
Rachel Ferrari was instructed by Ben Henry of Jonas Roy Bloom.