08 February 2023
Paul Harrison -v- HMRC
In Paul Harrison v HMRC  UKUT 00038 (TCC), the Upper Tribunal dismissed an appeal against a discovery assessment. The taxpayer had argued that the assessment could be challenged on the grounds of staleness notwithstanding the Supreme Court’s decision in HMRC v Tooth  UKSC 17. The Upper Tribunal stated at  that the doctrine of staleness was not like Monty Python’s parrot (“not dead, only sleeping”) but was deceased.
Sadiya Choudhury acted for HMRC.
To view a copy of the decision please click here