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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Opening the Enquiry: statute: single enquiry - case owner

Where more than one person may be involved in the enquiry, one person should be designated the case owner at this point. This person should be responsible for co-ordinating all work on the case. As case owner, you will not necessarily be the person who carries out all the work appropriate to the case. It may be that another officer in the same office or another office will be responsible for dealing with correspondence on a particular issue. However, you should retain an oversight of the enquiry and will be responsible for issuing the opening and closing notices.

You should never open an enquiry into a director’s return without first obtaining clearance from the person responsible for dealing with the company’s return.

Before beginning an enquiry you should ensure that all areas of the return have been risk assessed so that all those which need checking are identified. You should avoid taking a blinkered approach to the enquiry and should use it as an opportunity to consider other aspects of the taxpayer’s compliance with their obligations. For example, filing returns for other years or paying tax, or complying with obligations as an employer.

This may involve consideration of whether specialist offices such as SI, see EM0320, or HNWU, see EM0860, have an interest in the case, as they too are bound by the single enquiry rule. You should be able to identify these cases by checking the entries in Self Assessment Notes.

Once the decision to issue a notice of enquiry has been made, the enquiry should be opened in the following way.

You should confirm that the time limit for starting an enquiry has not passed EM1506 and that an enquiry into that year has not already been opened and closed. If either of these circumstances applies you should consider whether you may have grounds for making a discovery EM3250+.

You should prepare an enquiry plan, detailing the risks identified and showing how and by whom each of those risks will be addressed.

The case owner should send the written notice of intention to enquire to the taxpayer. The notice should normally be included in a letter to the taxpayer which also sets out the information etc that you need in order to check the return, see EM1560.

Note: Although there is no statutory form of words for opening an enquiry, you should use where available the appropriate letter in SEES.