1. This Statement of Practice explains, in relation to income tax, corporation tax and capital gains tax, the circumstances in which HM Revenue and Customs seeks to recover tax when a person has not been assessed or has been inadequately assessed. The Statement does not cover cases where there may have been fraud or negligence by or on behalf of the taxpayer.
2. The Statement draws attention to the relevant statute and case law, in particular to the cases of Cenlon Finance Co Ltd v Ellwood [ AC 782] and Scorer v Olin Energy Systems Ltd [ BTC 181].