King v Revenue and Customs (INCOME TAX - loan contractor scheme - validity of discovery assessments - s29(5) TMA) [2026] UKFTT 394 (TC) (13 March 2026)
HMRC demonstrated that, for each relevant tax year, an officer could not have been reasonably expected to be aware of the insufficiency of tax based on information made available, satisfying s29(5) TMA; discovery assessments were valid and appeal dismissed.
- Citation
- [2026] UKFTT 394
- Parties
- Appellant: Jonathan King; Respondents: The Commissioners for His Majesty's Revenue and Customs
- Jurisdiction
- United Kingdom
- Judgment Date
- 13 March 2026
- Procedural Posture
- Income Tax Appeal / First Tier Tribunal Judgment
- Outcome
- Appeal dismissed
- Legal Topics
- Discovery Assessments, Contractor Loan Schemes, Tax Avoidance, Self Assessment, Employment Income
Case Brief
Summary, issues, holding and outcome
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Parties
Jonathan King
Appellant
The Commissioners for His Majesty's Revenue and Customs
Respondents
Procedural Posture
Income Tax Appeal / First Tier Tribunal Judgment
Legal Issues
- 1 Validity of discovery assessments under s29 Taxes Management Act 1970
- 2 Whether HMRC met the condition in s29(5) TMA for issuing discovery assessments
Ratio Decidendi
HMRC demonstrated that, for each relevant tax year, an officer could not have been reasonably expected to be aware of the insufficiency of tax based on information made available, satisfying s29(5) TMA; discovery assessments were valid and appeal dismissed.
Court Disposition
Appeal dismissed
Orders
- Discovery assessments upheld
- Right to apply for permission to appeal within 56 days
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