Supreme Court finds taxpayer is estopped by convention from denying validity of HMRC’s enquiry (Tinkler v HMRC)

Published on: 30 July 2021

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Specialist Tax Regulatory Materials

Article summary

The Supreme Court has unanimously allowed HMRC’s appeal, holding that the taxpayer, Mr Tinkler, was estopped from denying that a valid enquiry had been opened into his tax return. Adam Craggs, partner at RPC, and Elizabeth Small, partner at Forsters, comment on the Supreme Court's judgment.

Jurisdiction(s): England, Northern Ireland and Wales

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