Offshore trust beneficiary wins HMRC time limit extension

Mark Battersby
clock • 1 min read

The beneficiary of an offshore trust has won a time limit extension from HMRC for raising a discovery assessment, in a court case ruling by First Tier Tribunal (FTT). In James Scott v HMRC [2023] TC08784, the FTT confirmed the extended time limits for Discovery Assessment applying to the Requirement to Correct (RTC) rules, according to a briefing note on 21 September by Rossmartin.   The taxpayer was the beneficiary of an interest-free loan from an offshore trust, which created a taxable benefit.  Prompted by the Requirement to Correct rules to report a UK tax liability that result...

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