Many disputes concern cases where HMRC allege that the returns do not reflect all the positive-rated supplies made. The relevant factors depend on the nature of the business and any reliable records which are available. HMRC often prepare mark-up calculations. These add a mark-up to the recorded or known purchases to arrive at the ‘correct’ takings subject to certain allowances. These calculations can be very detailed, lengthy, complex and time consuming. The allowances, which may be needed and may often be estimated, include the following:

(1)weighting of the mark-up on the purchases according to the proportions involved;

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