Supreme Court decision on Tinkler v HMRC
The Supreme Court (Lord Hodge, Lord Briggs, Lady Arden, Lord Burrows, Lady Rose) handed down judgment on Friday, 30 July 2021, allowing HMRC’s appeal in relation to whether the Respondent is estopped by convention from denying that HMRC had a valid enquiry when HMRC had sent the notice to the wrong address and the Respondent’s accountants had interacted with HMRC on the basis that an enquiry had been opened.