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HM Revenue and Customs Brief 17/11


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Issued on 01 April 2011

HM Revenue & Customs (HMRC) guidance on Special Relief


From 1 April 2011, equitable liability will be replaced by a new, statutory, special relief. HMRC have now published its guidance to officers regarding the new relief.

Who needs to read this

Taxpayers who have received Income Tax or Corporation Tax determinations from HMRC and whose tax affairs have been in arrears for several years. Tax advisers who represent clients in such a position.


Previously, where customers had 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. This practice was known as 'equitable liability'. The purpose of the equitable liability concession was to provide a 'relief of last resort' for certain taxpayers, particularly those vulnerable taxpayers who are unable to fully engage with the tax system, for a number of different reasons.

What is changing

From 1 April 2011, 'equitable liability' will be replaced by a new, statutory, 'special relief'.

HMRC’s guidance on the new relief can be found here new Self Assessment Claims manual guidance (PDF 53K). The guidance will be incorporated in HMRC Self Assessment Claims manual shortly.

HMRC will no longer accept new requests for equitable liability but will still continue to consider those claims for equitable liability received before that date.


All of the changes outlined in this brief take effect from 1 April 2011.

About the Author

© Crown Copyright 2011.

A licence is needed to reproduce this article and has been republished for educational / informational purposes only. Article reproduced by permission of HM Revenue & Customs.

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Article Published/Sorted/Amended on Scopulus 2011-04-06 11:13:54 in Tax Articles

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