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HMRC Had Power To Enquire Into Its Own Calculations

By Mark McLaughlin, October 2017
HM Revenue and Customs (HMRC) was entitled to enquire into the calculations of tax due in the appellant’s tax returns for the tax years in question, notwithstanding that the calculations were based on technical specifications provided by HMRC.

Summary

HM Revenue and Customs (HMRC) was entitled (under TMA 1970, s 9A) to enquire into the calculations of tax due in the appellant’s tax returns for the tax years in question, notwithstanding that the calculations were based on technical specifications provided by HMRC.

Background

The appellant claimed corresponding deficiency relief (CDR) (under ITTOIA 2005, s 539) for 2006/07 and 2007/08. His accountants used a software package supplied by a third party to produce the appellant’s tax returns for both years, including the calculation of tax due. 

HMRC provided technical
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