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The law requires that when an officer makes an assessment he must ensure that his assessment
is made to best judgement. That means fair, reasonable, honest estimates.
In direct tax and vat law, each case is considered on the evidence presented to HMRC.
What may be sufficient in one case for one reason or another may not be sufficient in another case.
The business was selected for a VAT audit as part of a restaurant taskforce project.
On 2 November 2014 HMRC carried out a test purchase.
On 30 January 2015 HMRC Officers Suzan Wong and Richard Moody carried out
an unannounced visit to the business premises and supervised cash up of takings.
This showed that 70% of the total takings of £2,345 for that evening were in cash.
At a meeting HMRC officers setting out their findings and explaining that they intended to issue a VAT assessment.
HMRC issued the tax assessments and VAT assessment based on a cash ratio of 61% for 6 years.