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FA 2019: voluntary returns

In a number of recent cases the First-tier tribunal has concluded that a return submitted voluntarily without a notice to file having been issued is not a valid return for the purposes of TMA 1970 s 8. See for example Patel & Patel v HMRC [2018] UKFTT 185 (TC) and Revell v HMRC [2016] UKFTT 97 (TC). HMRC revealed in the latter case that it receives on average 350 000 voluntary returns each year and its practice has always been to treat these as if they had been made in response to a formal notice. FA 2019 s 87 gives HMRC the legal authority to continue this practice.
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