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HMRC internal manual

International Manual

Double Taxation Relief: Anti avoidance legislation: Notices

Notices may be issued before or after a return is made and exceptionally may be made on a discovery basis after the return enquiry window has closed (see INTM170080). Notices are issued by the Commissioners of Revenue & Customs. After a return has been made, a notice may be issued only after an enquiry has been opened (in practice, the opening of the enquiry and the issue of the notice may be simultaneous).

  • The notice will include the following details:
  • the person to whom it is issued
  • the period to which it relates
  • the transactions to which the notice applies
  • HMRC’s view of the implications of the notice for the taxpayer’s liability to tax.

Once a notice has been issued, the taxpayer must consider what effect the legislation has on their tax liability in the same way as they consider any other relevant tax legislation. Although HMRC will set out its view of the effect of the legislation in the notice, the person should base their self assessment on their own view of their tax liabilities as calculated taking the legislation into account in respect of the specified transactions.