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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Working the Enquiry: Jeopardy Amendments: The Notice

For SA, use the Jeopardy Amendment Notice. You can find this in the ‘Forms and Letters’ sub-menu.

For CTSA you should use function RAMA in COTAX to enter the amended figures and issue the notice of jeopardy amendment (Company Manual (COM)). The COTAX output to the company will include the following message.

I consider that the amount stated in the company’s self assessment, as the amount of tax payable, is insufficient and there is likely to be a loss of tax to the Crown. This notice shows the amendments I have made to make good the deficiency. Any tax shown is due NOW. You are reminded that interest is chargeable on tax paid late. For more information please read the ‘Amendment’ section in the enclosed CT620 Notes.

If you do not agree the figures you should appeal in writing WITHIN 30 DAYS of the date of issue shown above, and may apply to postpone payment of any tax you consider is excessive.

Any appeal made cannot be heard or determined before completion of the enquiry.

The COTAX output will be delivered, as normal, through the postal service. If there are exceptional circumstances which mean that there would be a loss of tax if you did not immediately deliver the notice of jeopardy amendment to the company, rather than wait for service by post, you should prepare and issue the notice manually, in the following terms.

On [date] [I/Mr/Mrs/Miss/Ms] [name] gave you notice of [my/his/her] intention to enquire into the company tax return for the accounting period [….]. Those enquiries have not yet been completed. But in [my/his/her] opinion the tax of [£…] contained in the company’s self assessment is insufficient and unless the assessment is immediately amended to make good the deficiency there is likely to be a loss of tax to the Crown.

Accordingly I hereby give notice under Paragraph 30(1) of Schedule 18 to the Finance Act 1998 that I am amending your self assessment to [£…]. The additional tax due of [£…] is due now.

You may appeal against this amendment within 30 days of the date of this notice. Your appeal must be in writing. An appeal form is attached. If you appeal, you cannot ask for a review of my decision to issue this amendment, nor can you ask the tribunal to decide the matter until I have completed my enquiries. If you appeal, the additional tax remains payable but, if you consider you are overcharged to tax by this amendment, you may apply in writing within 30 days to postpone payment of the tax overcharged, pending settlement of your appeal. (You may change your application later if there is a change in circumstances.) You can use the attached appeal form to apply for postponement of any tax overcharged.

If the notice is to be issued within 9 months of the end of the period replace “NOW” with “on or before …….”, inserting the due date for the accounting period.

You will then need to input details on COTAX as before but prevent issue of the COTAX notice to the company (see on-line Company Manual (COM).