This short decision concerns HMRC's application for an order that arrangements entered into by the respondents were notifiable tax avoidance arrangements under the DOTAS scheme. The respondents in the case sought an order striking out HMRC's application on the basis that HMRC had...
The FTT has rejected the validity of HMRC's discovery assessment on the basis that there was no evidence that HMRC had actually made a "discovery" in the circumstances of the case:Lowe v HMRC[2024] UKFTT 826. The decision is a useful reminder of the burden on HMRC to demonstrate that a...