King v Revenue and Customs (INCOME TAX - loan contractor scheme - validity of discovery assessments - s29(5) TMA) [2026] UKFTT 394 (TC) (13 March 2026)

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

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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

  1. 1 Validity of discovery assessments under s29 Taxes Management Act 1970
  2. 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