Making and notifying assessments: bulk or global assessments
In situations where you are unable to allocate excise duty due to specific accounting periods or dates, or you have difficulty in doing so, you may make a “bulk” assessment. That is, an assessment that covers more than one accounting period or a range of dates.
The need to make a “bulk” assessment is most likely to arise where the events giving rise to the liability to excise duty are transaction based and it is not possible to determine exactly when the duty point(s) was reached.
However care should be taken when making such assessments. Make sure that you insert the start and end dates of the bulk assessment period on the assessment form (EX 601) as the absence of these dates may render the assessment invalid. You must also ensure that no part of the bulk assessment period falls outside the four-year assessment time limit as this will also make the whole assessment invalid.
A bulk assessment is considered in law to be a single assessment and so if any part is invalid, the whole assessment is deemed to be invalid. Consequently if a bulk assessment is invalid in any way, the whole assessment must be withdrawn. Depending upon the time that has elapsed, it might be possible for a new assessment to be made and notified. So long as the period is in time and you are still within the one year evidence of facts rule.
Having made a bulk assessment, it is best practice when notifying it, to include a schedule. The schedule should provide details of each transaction or event, which gave rise to a liability for duty and for each duty point a line on the schedule should be included which shows the amount of duty due in respect of that duty point.
Allocation of duty to specific duty points
When assessing excise duty from a person and there are no fixed accounting periods, but you are relying upon a specific duty point you should allocate the duty, where possible, to the date on which the liability arose.
If, however, it is not possible to do so, or you have difficulty in identifying the precise date on which the duty point and liability arose, you may
- use best judgement to allocate the duty to a range of dates on which the duty point could have arisen by whichever method is fair and reasonable taking account of the information known
- use best judgement to allocate the duty to a specific date on which it is known that liability to the duty had accrued (goods are in free circulation) by whichever method is fair and reasonable taking account of the information known.