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London School of Economics and Political Science v HMRC

What is a valid notification of an assessment?

In London School of Economics and Political Science v HMRC [2015] UKFTT 291 (17 June 2015) the FTT found that an assessment was valid even though it did not explicitly state the period to which it related.

The school applied against an assessment for period ‘00/00’ in the sum of £1 442 597 for the recovery of an amount of money repaid to it by HMRC representing incurred VAT.

The issue was whether the notification of the assessment – comprising VAT form 655 a letter from HMRC dated 4 September 2012 and a letter from HMRC dated 9 September 2010 (to which the September 2012 letter referred) – was valid. This in turn depended on establishing the correct prescribed accounting period for the purposes of an assessment made under VATA 1994 s 73(2); and deciding whether an assessment specifying...

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