“Tooth nails the meaning of ‘deliberate’ and eradicates ‘staleness’” by Tony Monger, Director, Tax Investigations, Mazars

Tony Monger explains the implications of a Supreme Court ruling that found against HMRC, and also calls into question the taxman’s behaviour in the case

The long-running saga of Raymond Tooth versus HMRC reached its conclusion in the Supreme Court recently when the Court dismissed the assessment that HMRC had made upon him. 

The case has been keenly followed by tax professionals through the First Tier and Upper Tribunals and the Court of Appeal because it focused on two important principles – the question of what constitutes a deliberate inaccuracy in a return and the question of whether a ‘discovery’ can become ‘stale’.

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