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Special relief replaces ‘equitable liability’: Brief 17/11

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HMRC’s practice of ‘equitable liability’ provided a ‘relief of last resort’ for certain taxpayers who were unable to fully engage with the tax system.

It was applied where there was no statutory remedy to adjust an excessive assessment or displace a determination because the time limit for submitting a return had passed. HMRC would in some cases be prepared not to pursue their legal right to recover the full amount due.

The practice is replaced with effect from 1 April 2011 by a new, statutory ‘special relief’,’ HMRC said in Revenue & Customs Brief 17/11.

HMRC guidance on the new relief will be added to the Self Assessment Claims Manual.