Commentary

I11.321 Restrictions on recovery of tax

IHT, trusts and estates

I11.321 Restrictions on recovery of tax

Recovery of tax

I11.321 Restrictions on recovery of tax

HMRC cannot take legal proceedings for the recovery of any tax or interest due from any person unless the amount has been agreed in writing with that person or has been determined and specified in a notice of determination1. If an appeal against a notice of determination is pending HMRC can only seek to recover agreed, undisputed amounts. This does not apply if the appeal is taken further. In such cases the disputed tax is payable but can be adjusted after determination of the appeal2. Any tax that is the

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