A discovery assessment in connection with a tax avoidance scheme involving capital losses as a result of the taxpayer entering into tax planning arrangements was held to have been validly made.
Summary
A discovery assessment issued by HM Revenue and Customs (HMRC) in connection with a tax avoidance scheme involving capital losses as a result of the taxpayer entering into tax planning arrangements was held to have been validly made.
Background
The appellant's tax return for 2003/04 claimed relief for a capital loss of over £2.6 million. The ‘additional information’ box of his return indicated that the loss arose from arrangements involving the surrender of capital redemption contracts.
HMRC commenced an investigation into the appellant's affairs in October 2006. HMRC issued an
