Further to their other recent update on this topic in the Compliance Handbook, HMRC have now added the following paragraph under the heading of “Assessing Time Limits: Extended time limits: What is deliberate behaviour”:
“A person who submits a document containing a deliberate inaccuracy might assert that they did not intend to cause a loss of tax. For the purpose of assessing this loss of tax, the person or any persons acting on behalf will be treated as deliberately causing the loss of tax if they consciously intended to mislead HMRC.”
Related content from Claritax Books
Discovery Assessments, by tax barrister Keith Gordon, is a detailed, clearly written guide to the law and practice in this area. Based on the author’s personal involvement in many leading cases, the book contains much practical advice explaining when and how such assessments may be challenged.