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

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