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HMRC internal manual

VAT Assessments and Error Correction

HM Revenue & Customs
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Circumstances that affect assessments: Dissolved traders

Although legislation does not make it clear that an assessment made in respect of a company that did exist but no longer exists is invalid, it is certainly to no avail.

Assessments are generally made to establish a debt that can be pursued as a debt due to the Crown, so that HMRC can recover tax, duty, interest, penalties, etc.

This is unlikely in the case of a dissolved company. Consider whether it is cost effective to reinstate a dissolved company in order to make an assessment and establish a debt for collection.

In most cases it is unlikely that reinstatement would be cost effective.

In exceptional circumstances, where for example assets are identified that would make it worthwhile to raise an assessment, it may be possible to reinstate a dissolved company and in such a case you should refer to the Civil Recovery guidance manual.

Any assessment raised would need to follow the manual procedures at VAEC3560.