HMRC internal manual

Specialist Investigations Operational Guidance

Statutory basis for closing an investigation: assessments: care to be taken when assessments are raised

It is essential when assessments are needed to conclude a case by determination of civil liability to take special care to ensure that the assessments are raised in exactly the form we want so that they can be properly defended at contentious appeal. When assessments are raised at the request of SI the Investigator should ensure that this is done precisely as instructed.

Often the critical decision in a contentious appeal is the choice (which sometimes is finely balanced) of which person will be assessed, to what sources of income, for which periods. Alternative bases of assessment may have to be considered.