84Meaning of “tax position”E+W
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(1)In this Part, “tax position”, in relation to a person, means the person's position as regards any devolved tax, including the person's position as regards—
(a)past, present and future liability to pay any devolved tax,
(b)penalties [tax credits], interest (including interest on penalties [and amounts payable in respect of tax credits] ) and other amounts that have been paid, or are or may be payable, by or to the person in connection with any devolved tax, and
(c)claims or notices that have been or may be made or given in connection with the person's liability to pay any devolved tax [or any amount in respect of a tax credit],
and references to a person's position as regards a particular devolved tax (however expressed) are to be interpreted accordingly.
(2)References in this Part to the tax position of a person include references to the tax position of—
(a)an individual who has died, and
(b)a body corporate or unincorporated association that has ceased to exist.
(3)References in this Part to a person's tax position refer to the person's tax position at any time or in relation to any period, unless otherwise stated.
(4)References to checking a person's tax position include references to carrying out an investigation or making an enquiry of any kind.
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