Disclosure, Information Notices And Discovery, April 2013

1. Introduction

This briefing note outlines the post April 2009 situation concerning discovery, information notices and discovery assessments in the light of the following tax cases:

HMRC's statement of practice 01/06 on self assessment and finality is also reproduced in full.

2. Discovery

Under the discovery provisions of the Taxes Management Act 1970 s29, HMRC may make a discovery assessment where they become aware that:

• income or gains that ought to have been assessed have not been;
• an assessment is, or has become, insufficient; or