Discovery Assessments: Taxpayer win in the FTT

In the matter of Realbuzz Group Ltd v HMRC the Tribunal has allowed the taxpayer’s appeal against HMRC’s discovery assessment in relation to a claim for R&D relief. The appeal was on the sole basis that, on the information made available to HMRC, they could reasonably be expected to have been aware of the excessive relief before they ceased to be entitled to give notice of enquiry. The decision includes a careful consideration of the principles relating to that test.

Edward Hellier acted for the Taxpayer.