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, based on information available at the relevant times, a hypothetical officer could not reasonably have been expected to be aware of the insufficiency of tax; therefore, the condition in s29(5) TMA was met and the discovery assessments were valid.
- Citation
- [2026] UKFTT 394 (TC)
- 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, Section 29 Taxes Management Act 1970, 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(5) TMA
- 2 Adequacy of disclosure for s29(5) TMA
- 3 Taxability of contractor loan scheme payments as employment income
Ratio Decidendi
HMRC demonstrated that, based on information available at the relevant times, a hypothetical officer could not reasonably have been expected to be aware of the insufficiency of tax; therefore, the condition in s29(5) TMA was met and the discovery assessments were valid.
Court Disposition
Appeal dismissed
Orders
- Discovery assessments upheld
- Right to apply for permission to appeal within 56 days
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