Determinations

A revenue determination in respect of direct tax:

1. •

   is issued by HMRC where a taxpayer fails to file a tax return

2. •

   is based on an HMRC estimate of the amount of tax due

3. •

   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

4. •

   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?, ...