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HMRC internal manual

Enquiry Manual

Reopening Earlier Years: Introduction


FA98/SCH18/PARA 41

Enquiries into tax returns under SA are opened under the formal enquiry powers of Section 9A (individuals), Section 12AC (partnerships), Schedule 1A (claims) and Schedule 18 Finance Act 1988 (companies) and will be closed under the provisions of TMA70/S28A, TMA70/S28B, paras 7 and 8 Schedule 1A TMA 1970 or para 32 and 34 Schedule 18 FA 1998. Wherever possible you should always open an enquiry under the SA provisions.

However, you will need to extend your enquiry into earlier years when there is evidence that there are omissions or when you start a new investigation into a year where the time limit to open SA enquiries has passed. In either case you will need to invoke the power to make discovery assessments.

The instructions are arranged as follows:

  • Discovery for SA (CTSA and ITSA) years EM3250+
  • Discovery for pre SA years EM3280+
  • CTSA discovery determinations EM8040 

Guidance on when to reopen earlier years can be found at EM2000+ and EM3309.