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14 June 2011
A taxpayer’s liability was determined by HMRC and these determinations are now more than four years old
We have a client who came to us having managed to collect a few tax determinations for earlier years two of which were already out of date under the new four-year deadline. He had moved house in the meantime but not notified HMRC whose attitude is that he knew he had to submit tax returns anyway.
He had previously had small refunds and our calculations indicate that his tax liabilities for these later (determined) years just about break even.
However the determinations for the two out of date years total over £10 000 and HMRC are adamant that they must stand. Our questions are as follows.
- First is it fair for HMRC to vastly over-estimate someone’s tax liability when the determination provisions are there as a means of collecting what it due to the Treasury and...
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