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In Victoria Carter & Peter Kennedy v HMRC [2021] UKUT 0300, the Upper Tribunal (UT) concluded that white space disclosure was insufficient to prevent a discovery assessment being raised by HMRC.  The disclosure suggested that a tax scheme had been operated but did not provide details.

The FTT dismissed the taxpayers' appeal against the discovery assessment as:

The taxpayers' appeal to the UT was dismissed as:

Useful guides on this topic

SDLT: Residential property & dwellings
What is residential property for Stamp Duty Land Tax (SDLT)? What tax rate applies? What garden and grounds are subject to higher rates of SDLT?

SDLT: At a glance, Stamp Duty Land Tax, rates & allowances
What is Stamp Duty Land Tax (SDLT)? What are the rates of Stamp Duty Land Tax (SDLT)?

Discovery Assessment
When can HMRC issue an assessment outside of the normal statutory time limits? What conditions must be met? What are your rights of appeal and defences?

Discovery Assessments: At a glance
This is a freeview 'At a glance' guide to Discovery Assessments.

How to appeal an HMRC decision
Disagree with an HMRC decision? How to appeal, what type of decision can you appeal and what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

External links

Victoria Carter & Peter Kennedy v HMRC [2021] UKUT 0300


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