Where an assessment has been made, and no appeal has been made against such assessment or an unsuccessful appeal has been made, the VAT assessed is recoverable as a ‘debt due to the Crown’. This follows from the wording of VATA 1994, s. 73(9), which states:

‘Where an amount has been assessed and notified to any person … it shall, subject to the provisions of this Act as to appeals, be deemed to be an amount of tax due from him and may be recovered accordingly, unless, or except to the extent that, the assessment has subsequently been withdrawn or reduced.’

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