Determinations

Determinations

A revenue determination in respect of direct tax:

•
is issued by HMRC where a taxpayer fails to file a tax 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 direct tax revenue determination. As noted in Practice Note: What is a revenue determination for direct tax purposes?—How can a revenue determination be displaced?,

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

TAKE A FREE TRIAL

Latest Private Client News

Prepare now for new automatic disqualification criteria coming 31 August 2025

The Scottish Charity Regulator (OSCR) has published guidance on the new automatic disqualification rules, which will come into force on 31 August 2025 under the Charities (Regulation and Administration) (Scotland) Act 2023. The changes extend disqualification criteria beyond trustees to include senior management roles, and they introduce new grounds for disqualification, such as terrorism-related offences and inclusion on the sex offenders register. OSCR will begin accepting waiver applications from 30 June 2025, prioritising individuals already occupying affected positions prior to the implementation date. These rules complement the existing restrictions on undischarged bankrupts and on those with protected trust deeds.

Modernising Wills—final report recommendations to modernise Wills law to promote testamentary freedom

Private Client analysis: On 16 May 2025, the Law Commission published its final report, Modernising Wills Law. Written by Matthew Duncan, partner and head of Private Wealth at Druces LLP.

Call for evidence on the tax treatment of carried interest – Government response and policy update

HM Treasury has published a Government response and policy update regarding the tax treatment of carried interest following a call for evidence. This update details the implementation of a revised tax regime, which will bring all carried interest within the income tax framework from April 2026.