Thursday 29 June 2017
Gareth Clark v HMRC [2017] UKFTT 392 (TC)
Jonathan Davey QC has been successful in an important tax / pensions First-tier Tribunal case regarding the meaning of “discovery” in the context of HMRC tax assessments. This followed Jonathan’s earlier and related success before First-tier Tribunal in the same appeal ([2016] UK FTT 630 (TC)) in relation to the meaning of “payment” and “in respect of” in the context of the unauthorised payment legislative regime regarding registered pension schemes (Finance Act 2004).