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HMRC internal manual

Enquiry Manual

Reopening earlier years: assessments: concealed sources

Before you make an assessment on a concealed source of income this must be authorised by the appropriate Authorising Officer. Such assessments must be authorised by the Authorising Officer responsible for authorising penalty assessments and determinations. This will normally be your manager.

When your taxpayer’s spouse, civil partner or domestic partner is a director of the same company or a partner in the same partnership, you may need to consider opening a linked enquiry, see EM8207 for linked company enquiries and EM7005+ for linked partnership enquiries.

A premature assessment may disclose HMRC’s knowledge of a concealed source and the taxpayer, when eventually challenged, might limit the disclosure to matters directly connected with that source.

Where you hold information obtained under a statutory power, you may disclose it if necessary to forward your enquiry, for example

  • to the taxpayer or agent to break an impasse
  • in proceedings before the tribunal.

If the information was not obtained under a statutory power see IDG30000.