Following the Supreme Court’s decision in Tooth, questions remained as to the type of knowledge a taxpayer must have when it comes to deliberate inaccuracies in documents.

The Upper Tribunal, in CPR Commercials Ltd, recently provided further clarity and confirmed that "blind-eye" knowledge of an inaccuracy would be sufficient. However, the issue of whether recklessness as to accuracy would be sufficient (a question expressly left open by the Supreme Court) has not been engaged with in the same manner, and there remains uncertainty in the area.

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