BKM209300 - Bank compensation restriction: commencement: role of CCM and HMRC case team
In all cases, we would expect banks to be discussing these issues with their Customer Compliance Manager (CCM) to reach a reasonable result.
HM Revenue and Customs should not seek to disturb an allocation of expenses simply because it delivers a more favourable outcome to the customer than a strict time apportionment. Equally, HM Revenue and Customs would not expect banks to make the calculation under several methodologies and then choose the one which delivers the most favourable result.