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Commentary

V5.134 Further and supplementary VAT assessments

Part V5 Compliance, enforcement and appeals

The amount of tax, penalties, interest or surcharge notified on an assessment may be less than the amount which is properly due. In such cases, HMRC is entitled to assess the additional amount due under three separate provisions1. A general power applies where the proposed assessment (known as a 'supplementary assessment') is to be made within the two-, four- or 20-year time limits2 specified in relation to particular conduct. A more restrictive power applies where the proposed assessment (frequently referred to as a 'further assessment') is to be made in relation to tax outside the prescribed two-year time limit. Further assessments may also be made in respect of interest and penalties accruing on a daily basis. An assessment may also be increased by way of a tribunal direction in certain circumstances3. These provisions are described below.

Supplementary assessment

HMRC may make a supplementary assessment if4:

  1. Ìý

    •ÌýÌýÌýÌý an amount has been assessed in respect of tax or penalties and

  2. Ìý

    •ÌýÌýÌýÌý it appears to HMRC

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