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HMRC internal manual

Enquiry Manual

Working the enquiry: reviewing earlier years: outstanding returns: determination of tax: determination strategy

Only Debt Management and Banking (DMB) can make a determination.

Where you have an open enquiry (including enquiries arising from campaign or task force cases) and you need DMB to raise any determinations, you must provide DMB with all the relevant information they need. This will provide assurance that determinations are being used effectively and the correct amounts are being determined.

For guidance about how to calculate the amount to be determined, see EM2029a.

DMB will not issue more than one determination for the same taxpayer at the same time if the only reason for your request is that more than one return is outstanding.

There may be circumstances when

  • more than one determination is required for the same taxpayer at the same time for other reasons or
  • determinations are required for periods before the start of the late filing penalty regime, under FA09/SCH55, see CH61120.

In these circumstances, DMB will consider requests to issue more than one determination. In addition to following the guidance at EM2029b, you must send DMB an explanation why you require more than one determination.

If you are dealing with a campaign or taskforce case, there should already be arrangements with DMB to establish timings and volumes before any individual determinations are requested.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)