INTM620430 - Offshore Receipts in respect of Intangible Property (ORIP): Recovery of tax from related persons: Payment Notice: Effects

ITTOIA05/Ch2A/S608P

Recovery of unpaid tax and interest

A notice issued under section 608O has the effect, for recovery purposes, as if it were a notice of assessment of an amount of tax due from the taxpayer. This means that interest on any unpaid tax runs from the original due date. Any pending appeals against the original assessment does not affect the due date of the unpaid tax and interest arising from a notice issued under section 608O.

Appeals

The section 608O notice is not treated as a notice of assessment for appeal purposes. A person issued with a section 608O notice may appeal against the notice only on the grounds that they do not fall within the definition of relevant person, (see INTM620410).

Only the taxpayer may appeal against the original assessment to tax charged under section 608A. The taxpayer’s right of appeal is covered further in INTM620440.