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HMRC internal manual

Enquiry Manual

Working the Enquiry: Closure Applications: Consequences of Tribunal Decision on Other Years

The giving of a tribunal’s direction in respect of a year does not extend to other years (unless a direction is also given for those years, where the return is the subject of an SA notice).

If you have already extended your enquiries into earlier years’ returns (whether for a pre-SA year, an SA year or a mixture of both) you can continue to pursue those enquiries.

If however you have not yet discussed earlier years’ liabilities with the taxpayer or agent, you should only do so following a direction if the conclusions you have already been able to draw about the return under enquiry cast doubts on the accuracy of earlier years’ returns, or if you could make a discovery assessment on the basis of other information relating to those years which is in your possession.