Once an HMRC determination has been made and issued to the purchaser (see ¶100-200), the purchaser may still make a return with respect to the transaction in question; in that case, the return supersedes the determination, but only if the return is made no later than the later of:

four years after the power to make the determination first became exercisable; and

12 months after the date of the determination

(Sch. 10, para. 27(1), (2)).

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