The deadline runs from the date of the letter. An appeal must usually be made within 30 days of the date on the document, not from when it was received or read. A late appeal is accepted only with HMRC's agreement or the tribunal's permission, and payment is not suspended unless postponement is applied for.

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The decision rests on the records. HMRC's decision is based on the returns and information it holds for the tax year in question. What matters is what lies behind the figures that were submitted.

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Responsibility stays with the taxpayer. From the moment you registered as self-employed or were appointed a company director, responsibility for the accuracy of your tax affairs rests with you. It does not pass to a contractor, a third party or whoever previously prepared your returns.

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The time limits are long. The standard time limit is four years; six years for careless errors; up to twenty years where an inaccuracy was deliberate; and up to twelve years for offshore matters.

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Leaving the UK does not end the liability. A change of tax residence does not extinguish a UK tax debt. Under international agreements, HMRC may seek recovery abroad.

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An unanswered assessment becomes final. If no appeal is made within the time limit, the assessment stands and HMRC may proceed to collection.

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A settlement has lasting effect. An appeal settled by agreement has the same effect as a tribunal decision. Nothing should be agreed or signed until its consequences are understood.

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Interest runs throughout. Late payment interest accrues from the date the tax was due until it is paid.

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HMRC demands, discovery assessments, enquiries and CIS disputes form the core of the practice's work. HMRC's authority is not in question: the work establishes whether a demand accords with the facts and the law, and whether there are lawful grounds to challenge it. All matters are handled in confidence.

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