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Corrective action form could not be used to make further consequential tax return amendments

By Mark McLaughlin, October 2025

The taxpayer’s corrective action form could not be used to make further consequential amendments to his self-assessment return, and the conclusion in an HMRC enquiry closure notice that no amendment was required to the tax return was not appealable. 

The appellant’s tax return for 2007/08 was filed on 19 August 2010. The calculation of income tax due was £0 and the return included (as relevant): (1) ‘other taxable income - before expenses and tax taken off’ (box 15) of £1m; (2) a net loss in self-employment (trading in used cars) of £1,108,228 (box 63); (3) a claim for £1,025,390 of the losses to be set against other income for the same tax year; (4) a claim for £82,838 of the losses to be carried back to previous tax years; and (5) a disclosure that the ‘Working Wheels’ tax avoidance scheme had been used. 

During an HM Revenue and Customs (HMRC) enquiry into the appellant;

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