Wednesday 23 November 2022
This is a second appeal. By appellant’s notice filed on 20 September 2021, HMRC appeals, with the permission of Mrs Justice Falk and Judge Timothy Herrington, their decision of 30 June 2021 whereby they dismissed HMRC’s appeal.
The appeal concerns HMRC’s powers to raise a discovery assessment where a taxpayer is liable to the High Income Child Benefit Charge and failed to notify their liability to income tax. The relevant discovery assessment power is found in s.29 of Taxes Management Act 1970.