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HMRC internal manual

Compliance Handbook

How to do a compliance check: types of compliance check: pre-return checks: restrictions on using information and inspection powers provided by Schedule 36 Finance Act 2008

There are specialised powers relating to UK taxes that the Schedule 36 information and inspection powers have not replaced.

CH21070 contains important guidance to help you decide whether you can use either Schedule 36 or a specialised power when you are carrying out a compliance check. You should not carry out a pre-return check where it would not be appropriate or proportionate to use Schedule 36 powers instead of a specialised power.

For example, powers exist under SI 1998/3175 para 10 to enquire into the quantum of quarterly instalment payments of corporation tax (QIPs) after the statutory filing date for the return. It is not appropriate or proportionate to make a pre-return check, or use the powers provided by Schedule 36, to check the quarterly instalment payments of companies, see EM8320.