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HMRC internal manual

Enquiry Manual

Working the Enquiry: Jeopardy Amendments: Conditions

TMA70/S9C

FA 98/SCH 18/PARA 30

Where, during the course of an enquiry, you have reason to believe that

  • the amount of tax payable stated in the self-assessment is insufficient, and
  • that unless the assessment is immediately amended there is likely to be a loss of tax to the Crown

you may by notice to the taxpayer amend the self-assessment to make good the deficiency so far as the amendment relates to any matter still under enquiry. Where a partial closure notice has been issued in relation to any matter to which your amendment relates, you will need to consider discovery.

There is no restriction on the number of jeopardy amendments that can be made, so it would be possible to make successive amendments in respect of a single self-assessment. In practice such cases are likely to be rare and will only occur where further facts emerge during the course of an enquiry which leads you to think that the first jeopardy amendment was based on a considerable underestimate of the tax due.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000)
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  • (This content has been withheld because of exemptions in the Freedom of Information Act 2000) (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

For guidance on how to make a jeopardy amendment, see EM1954 and SAM21010.