Determinations

Determinations

A revenue determination in respect of direct tax:

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is issued by HMRC where a taxpayer fails to file a tax return
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is based on an HMRC estimate of the amount of tax due
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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

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