ECL32100 - Enforcement: Assessments: Scope of assessments
If HMRC believes that a person was due to pay the ECL to them, but there has been a relevant failure (see [ECL32200]), HMRC may assess the amount of the levy due from that person for that financial year to the best of HMRC’s judgement.
HMRC may consider information such as the ECL liabilities in previous years and available financial accounts to make a reasonable estimate of what banding the customer will fall in.
In most cases it will be reasonable to assume that the customer was engaged in the regulated activity for the whole financial year, unless HMRC is in possession of information to the contrary.
An assessment must be given in writing, stating both the date on which the notice is given and the time limit within any appeal against the assessment can be made.