C.7.Random selection plays an important part in the new regime but, as hitherto, the vast majority of enquiries are selected on the basis that tax is thought to be at risk. Taxpayers have a right of appeal if they do not agree with the Revenue s findings, and have the right to ask the Commissioners to issue a completion notice to bring the enquiry to an end. The Revenue also retain general investigative powers. Interest C.8 Interest is chargeable under TMA 1970 s.86 on any amount of tax unpaid at the due date for payment, whether payment on account or balancing payment. Where an amendment to a self-assessment or a discovery assessment is made after the filing date, interest runs from the annual filing date for the relevant tax year.
Interest applies to all late payments of tax, surcharges or penalties.
Unpaid surcharge attracts interest 30 days after it has been imposed. The Board has the power to mitigate surcharges. For most penalties, the Commissioners can confirm, increase, decrease or set aside the determination. Late filing C.13 Automatic fixed penalties apply if the time limits for the filing of tax returns are not met. If the failure to file the return continues for more than twelve months after the filing date an officer of the Board may impose a tax-geared penalty.