Gareth Clark v HMRC [2017] UKFTT 392 (TC)

Jonathan Davey QC has been successful in an important tax / pensions First-tier Tribunal case regarding the meaning of “discovery” in the context of HMRC tax assessments. This followed Jonathan’s earlier and related success before First-tier Tribunal in the same appeal ([2016] UK FTT 630 (TC)) in relation to the meaning of “payment” and “in respect of” in the context of the unauthorised payment legislative regime regarding registered pension schemes (Finance Act 2004).

Read the decision here