V5.133 Global VAT assessments

The amount of tax notified to a person under VATA 1994, s 73(1) or (7)1 may relate to two or more prescribed accounting periods2. The document(s) sent or handed to the trader may comprise a notice of a separate assessment for each prescribed accounting period or a notice of a single assessment (known as a 'global assessment') for the prescribed accounting periods as a whole. A global assessment is, therefore, simply a single assessment for more than one prescribed accounting period rather than a series of assessments referable to individual prescribed accounting periods3. The distinction is important in relation to time limits for making an assessment4 and to an application for an appeal to be entertained without payment or deposit of tax5.

The question whether HMRC has made a global assessment or a number of separate assessments is a question of fact6 to be resolved by construing the document(s) concerned. Such documents are not limited to the formal notice of assessment (Form VAT 655) but include any schedules and letter or other document sent with, or in place of, it7. Indeed, it is important to understand that the assessment of the amount of tax considered to be due and the notification to the taxpayer are separate operations and therefore an assessment is not contained in

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial