beta This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Enquiry Manual

Opening the Enquiry: 'Discovery' Investigation Unavoidable

Where SA return is not currently open and no further returns are expected (for example, because the taxpayer has ceased self employment and become an employee who is not within SA) the only option will be to pursue the issue under the discovery provisions EM3250+.

For periods to which SA does not apply

  • an officer of HO grade or above has a continuing obligation under TMA70/S29 (old) to make an assessment accordingly if they are satisfied that a return (including the accounts and computations) is correct and complete
  • it remains necessary for the officer of HO grade or above to show grounds for dissatisfaction with the return before starting an investigation into the taxpayer.