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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Completion applications - consequences of tribunal's decision on other tax years

If the tribunal gives a direction in respect of a tax year, that direction does not extend to other years. A separate direction is required in respect of each year. If you have opened an enquiry into other years, you can continue to pursue those enquiries unless a direction is also given in respect of them. Note that, where you are also considering years earlier or later than the year under enquiry, the customer(s) cannot make a completion application in respect of any other year which is under examination. This is because the legislation does not permit customers to make an application to have an examination completed.

If however you have not yet discussed the entitlement or amount of the award for earlier years with the customer(s), you should only do so following the direction if

  • the conclusions you have already been able to draw about the year under enquiry cast doubts on the entitlement for earlier years, or
  • you could make a discovery decision relating to those years on the basis of other information in your possession.