8.1.1 Internal procedures

The legislation is silent as to any procedures that ought to be followed when a discovery assessment is made, and such matters are left for HMRCʼs own internal guidance.

One particular procedure worth noting is in cases where an assessment is made more than four years after the end of the tax year to which the assessment relates, what HMRC refer to as ‘extended time limit assessments’. In such cases, HMRCʼs guidance requires officers to obtain the authorisation of ‘the appropriate authorising officer’.

Any failure to comply with such a duty, however, would not render the assessment invalid.

Guidance: CH 53300

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