07 December 2022
HMRC v Jason Wilkes
Income Tax – High Income Child Benefit Charge – Discovery assessments
The Court of Appeal held that, where a taxpayer had not submitted a self-assessment return, HMRC could not issue a discovery assessment under TMA 1970 s 29(1)(a) in respect of an unpaid high income child benefit charge. The decision can be found here.
Richard Vallat KC appeared pro bono for Mr Wilkes with Marika Lemos of Devereux Chambers.