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HMRC internal manual

VAT Assessments and Error Correction

Recovery assessments: Schedule 9A paragraph 6(1) assessments

Schedule 9A VAT Act 1994 concerns the Anti - Avoidance provisions in relation to VAT group registrations. This section of the law enables us to issue Commissioners Directions in certain circumstances. The circumstances and the format of such directions are described in Schedule 9 para 1(1) to para 3(8) VATA94.

The time limits on issuing such directions are set out in Schedule 9A para 4(1) to 4(4).

An assessment may be required as a result of a Commissioners Direction and the law governing this type of assessment is set out in Schedule 9A para 6(1) to para 6(11).

The time limits for making an assessment are at para 6(6) which is reproduced below.

‘6(6) An assessment under this paragraph shall not be made-

      (a) more than one year after the day on which the direction to which it relates was given, or

     (b) in the case of any direction that has been withdrawn.’