Discovery assessments relating to the undeclared income of a tax agent were validly made, were issued in time because the taxpayer’s tax return inaccuracies were deliberate, and the quantum of the assessments were upheld (subject to a minor amendment for one of the relevant tax years).  

The appellant came to the UK and completed a university degree in 2008. He had purportedly been working since and only ever received PAYE income. On 9 July 2010, the appellant was set up for self-assessment due to a claim for repayment of employment expenses. On 30 May 2011, the appellant submitted his self-assessment return for the tax year 2010/11. On 27 January 2012, HM Revenue and Customs (HMRC) opened an enquiry into the return. On 12 June 2012, the appellant submitted his tax return for 2011/12. On 28 June 2012, HMRC opened an enquiry into that tax return. In July 2014, HMRC commenced a criminal investigation in respect of the appellant. Consequently, the