The following Tax practice note Produced in partnership with Philip Rutherford provides comprehensive and up to date legal information covering:
This Practice Note explains:
what a determination in respect of direct tax (ie a direct tax determination) is
when HMRC might issue a direct tax determination
the quantum of a possible direct tax determination
the time limits within which HMRC can make such a determination
the effect of such a determination on a taxpayer, and
the options available to a taxpayer to displace a direct tax determination
For the purposes of this Practice Note, except where expressly provided otherwise, a determination is used to refer to a direct tax determination.
For a practical guide on how to deal with a direct tax determination, see: Practical steps for dealing with a tax determination—checklist.
is issued by HMRC where a taxpayer fails to file a tax return in response to a notice requiring the taxpayer to file a return
is based on an HMRC estimate of the amount of tax due
is treated as though it were a tax return filed by the taxpayer, ie HMRC's estimate is the amount the taxpayer is liable to pay to HMRC, and
gives HMRC the opportunity to commence formal proceedings to recover the unpaid tax
There is no right of appeal against a determination in respect of direct taxes. Such a determination can only be superseded:
by an actual self-assessment return being submitted within the later
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