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HMRC internal manual

Excise Assessments Interim Guidance

Fraud and evasion cases: effect of assessment on criminal proceedings and restraint

Each case has different circumstances and you should consult the case solicitor prior to assessment action. Whether or not criminal proceedings or restraint action has actually commenced it is extremely important that any assessment is made and notified within the assessments time limits.

In many cases it will not be appropriate to enforce an assessment until criminal proceedings are concluded, because this may prejudice the case or assist a subsequent submission for abuse of process. However, it is desirable to consult the case solicitor, as recovery in certain circumstances may be possible.