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HMRC internal manual

Compliance Operational Guidance

Supporting Guidance: employer compliance: guidance by subject: commencing the compliance check: the records are used for SA

Some records that you look at may also have been used to complete:

  • the employer’s or contractor’s business return or
  • the individual director’s or employee’s SA returns.

This does not affect the right to see them under:

  • Regulation 97 or
  • Regulation 51.

These records have a duality of purpose and asking questions about them will not therefore be enquiries under:

  • Section 9A or
  • paragraph 24.

You should:

  • make sure that the employer/contractor is aware that these records are being reviewed to confirm that they are fulfilling their statutory obligations in accordance with the relevant Regulations.

You should not ask questions about specific entries in the accounts, but:

  • tailor the line of questioning to establish if

    • payments are made to, or
    • benefits provided for employees in specific circumstances.

If appropriate you should:

  • liaise with the SA or CT Caseworker if there is a need to open a S9A or paragraph 24 enquiry
  • follow the guidance at COG904530.