Revenue Note for Guidance
Where a person chargeable to tax by virtue of this Chapter proves that any amount in respect of which he/she is so chargeable is irrecoverable, or that the payment had been waived without consideration and the waiver was reasonably made in order to avoid hardship, the person chargeable is treated as if he/she was not entitled to receive the amount, and all necessary adjustments will be made to assessments, by way of repayment (notwithstanding the general time limit for making a claim for a repayment of tax contained in section 865) or otherwise. However, if the amount is subsequently realised, the person’s liability to tax for all relevant years of assessment is readjusted by amended assessment or otherwise.
Relevant Date: Finance Act 2019