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HMRC internal manual

Enquiry Manual

Opening the Enquiry: Discovery Investigation: Opening Letter

For instance, you may have said that the GPR seems low. The agent may come back with a host of possible reasons. They may not satisfy you. You must then point out that while any or all of what has been said could be the explanation you really need to find out from the taxpayer what actually occurred. If on the other hand the agent replied that he or she had been disquieted by the level of GPR and had conducted enquiries, you should evaluate the evidence which has been put together. In any case where a thorough job has been done which explains the apparent discrepancy, and you have no other reasons to be dissatisfied, you should agree the profits returned.

Apart from saying that you have started an investigation and why you have done so, you should use the opening approach to find out more about the accounts or return. You will want to find out what was available to the accountant to prepare the accounts or return and what inherent weaknesses there may have been in the record-keeping.