Appeal court to decide on HMRC discovery powers

The Court of Appeal has said it will hear the case of Derek Hankinson, who lost a tribunal based on his residency status. The first tier tribunal found Hankinson was resident in the UK for the year 1998/1999 in a case worth £30m. Hankinson appealed this decision based on the fact HM Revenue & Customs made a discovery assessment about his residency status six years after the tax year in question ended. Under HMRC's discovery powers, officers can make an assessment on previous years provided it fulfils one of two criteria - that the officer could not have reasonably expected to have bee...