Note: the Statement of Practice is reproduced below, with author comments in indented bold italics

General

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 (HMRC) seek 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.

There is no reason to think that HMRC’s approach is likely to be different in relation to SDLT or ATED which have been introduced in more recent years.

2.

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