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This Practice Note explains:

1. •

   what a determination (also referred to as a revenue determination) in respect of direct tax (ie a direct tax determination) is

2. •

   when HMRC might issue a direct tax determination

3. •

   the quantum of a possible direct tax determination

4. •

   the time limits within which HMRC can make such a determination

5. •

   the effect of such a determination on a taxpayer, and

6. •

   the options available to a taxpayer to displace a direct tax determination

For the purposes of this Practice Note, except where expressly provided otherwise, a determination is used to refer to a direct tax revenue determination.

For a practical guide on how to deal with a direct tax determination, see: Practical steps for dealing with a revenue determination for direct tax purposes—checklist.

It is important to note that a revenue determination is not the same as a discovery determination. A discovery determination is similar to a discovery assessment but a discovery determination (unlike a discovery assessment and unlike a revenue determination) only applies where