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HMRC internal manual

Enquiry Manual

Working the Enquiry: Jeopardy Amendments: Introduction

TMA70/S9C

FA98/SCH 18/PARA 30

Where a taxpayer will not agree to make a payment on account, and you are of the opinion that tax is at risk, you should consider making a jeopardy amendment.

Jeopardy amendment is the term used to describe an amendment made by an HMRC officer to the taxpayer’s self-assessment when an enquiry cannot yet be closed. The amendment replaces the taxpayer’s self-assessment (as there can be only one assessment for any year) and tax is therefore collectible on the basis of the amendment (subject to the taxpayer’s right to make a postponement application).

A decision to issue a jeopardy amendment will not, on its own, be sufficient reason to issue an early penalty determination or assessment, see EM5202. This will depend on whether you have sufficient information to make a decision about the taxpayer’s penalty behaviour.   

You will not normally have sufficient information to issue discovery assessments for earlier years at the same time as the jeopardy amendment. If you do have sufficient information, see EM2030+, then you should consider if it is preferable to close the enquiry.  

You should bear in mind that although the taxpayer cannot appeal against the jeopardy amendment itself, see EM1955, they can appeal against any discovery assessment of closure notice.

Guidance in this section covers

  • the conditions for a jeopardy amendment EM1952 
  • when to make a jeopardy amendment EM1953 
  • the notice itself EM1954 
  • appeals and postponements EM1955