Commentary

V5.138 Manner in which a VAT assessment is notified

Part V5 Compliance, enforcement and appeals

V5.138 Manner in which a VAT assessment is notified

V5.138 Manner in which a VAT assessment is notified

HMRC may assess the amount of tax due from a person and notify that amount to him1. The person to be notified is the person from whom the tax or other amount is due. This is the person on whom the assessment is made. For the persons on whom an assessment may be made, see V5.137.

Any notification given to any person for the purposes of VAT may be given by sending it by post in a letter addressed to that person at his last or usual residence or place of business2. This provision is permissive, not mandatory, and an assessment may therefore be notified in some other manner. In Aria3, the Court of Appeal held that two letters sent by HMRC notifying and quantifying the disallowance of input tax amounted to an

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