Swift justice

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The item Swift justice represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
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Summary: The author revisits the question of discovery assessments in the light of a First-tier Tribunal decision: Swift v HMRC. The case dealt with Mr Swift's entitlement to double taxation relief on the US tax paid in respect of the profits of a Delaware limited liability company, an entity that is treated as transparent for US tax purposes and, therefore, where the US tax on those profits would have been paid by Mr Swift personally. This article considers a subsidiary issue that arose in the case - HMRC's right to issue discovery assessments

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Summary: The author revisits the question of discovery assessments in the light of a First-tier Tribunal decision: Swift v HMRC. The case dealt with Mr Swift's entitlement to double taxation relief on the US tax paid in respect of the profits of a Delaware limited liability company, an entity that is treated as transparent for US tax purposes and, therefore, where the US tax on those profits would have been paid by Mr Swift personally. This article considers a subsidiary issue that arose in the case - HMRC's right to issue discovery assessments