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HMRC internal manual

VAT Assessments and Error Correction

Types of assessment: Prime assessments information: Inhibit issue of assessments for first periods example

In the case of Allan Bennett LON/96/907, who was compulsorily registered, a prime assessment was automatically calculated and notified in the absence of his first return.

The officer subsequently made an additional assessment to increase the total liability for the period to the correct amount. The tribunal found that the prime assessment could not have been made to best judgement as it had failed to take account of the information known to HMRC at the time it was made

‘In our judgement, when making the Central Assessment, the Commissioners failed to consider all the material and therefore failed to exercise their best judgement.’