NEW CLAIRE WINE LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2026] UKUT 00116 (TCC)
Upper Tribunal Tax and Chancery decision of THE HONOURABLE MR JUSTICE NICHOLAS THOMPSELL and JUDGE JONATHAN CANNAN on 12 March 2026
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Discovery assessments – extended time limit assessments – penalty for inaccuracy in a return – deliberate inaccuracy – whether deliberate inaccuracy necessarily involves dishonesty – whether HMRC required to specifically plead and prove dishonesty – whether the FTT erred in failing to explain how the appellant’s conduct might not involve dishonesty