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Practical guide to displacing determinations and making special relief claims.
KEY POINTS
- Deadline for displacing determinations made under TMA 1970 s 28C.
- Special relief claims must follow a specific format.
- The meaning of ‘unconscionable’ in First-tier Tribunal decisions.
- HMRC should reconsider the hard stance it takes in special relief cases.
As well as being the self-assessment deadline 31 January was significant for being the general deadline for displacing determinations for 2011/12 by filing a return for that year.
Most practitioners will encounter determinations (estimates of tax made under TMA 1970 s 28C) only occasionally perhaps for a new previously non-compliant client. At TaxAid determinations and claims to special relief to displace them are part of our daily routine.
The deadline for HMRC to make determinations and for taxpayers to displace them by filing a self-assessment...
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