Pattullo v Revenue and Customs: UTTC 14 Jun 2016

CAPITAL GAINS TAX – Discovery assessment; tax avoidance scheme involving capital redemption policies; when HMRC officer discovered that assessment was insufficient; whether there can be a series of discoveries; whether the discovery became stale; TMA 1970 s 29(1); whether officer could not have been reasonably expected to be aware of the insufficiency at earlier date; attributes of the hypothetical officer; what constitutes such awareness; tests to be applied; TMA 1970 s 29(5); Appeal dismissed


[2016] UKUT 270 (TCC), [2016] BTC 510, [2016] STC 2043




England and Wales

Capital Gains Tax

Updated: 05 August 2022; Ref: scu.567357