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HMRC internal manual

Excise Assessments Interim Guidance

Making and notifying assessments: time limit implications for making and notification of an assessment

It is settled case law that the assessment of the amount due and its notification to the person concerned are separate and distinct operations. This is based on the wording of the relevant legal provisions, eg Finance Act 1994 section 12(1), (1A) and (3).

The principle that an assessment and its notification are separate operations has been applied in a number of court decisions in VAT.

The legislation prescribes time limits only for the making of an assessment. It does not prescribe any time limit for the notification of an assessment. However, our practice - for all assessments made on or after 1 March 2001 - is that we will rely on the date of notification of an assessment as the material date for time limit purposes. This will demonstrate that the assessment was indeed made in time.