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HMRC internal manual

VAT Assessments and Error Correction

Power of assessment: Evidence of fact: Change in point of view about the same facts

A change of viewpoint about the same facts obtained on a previous visit does not provide new evidence for starting a fresh one year to run.

The one year starts from the date you obtained those facts enabling you to make the assessment to best judgement.

It follows that you cannot use a re-interpretation of facts obtained more than one year earlier to argue that the assessment would still be in time under Section 73(6)(b) VATA.

You may, however, still be in time to assess under Section 73(6)(a), the two year rule.