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HMRC internal manual

Enquiry Manual

From
HM Revenue & Customs
Updated
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Reopening Earlier Years: Assessments: Notification to Taxpayer

Where you intend to make an assessment for the purposes of making good a loss of tax or NIC you must take the following action.

Normal or extended time limits - explanation letter

Send the taxpayer (and the agent if they have one) an explanation letter - see ARTG2190 - when the notice of assessment is issued. In the explanation letter you must

  • explain the reasons why you are making the assessment,
  • tell the taxpayer about their right to appeal against the assessment and, if they wish, ask for a review of our decision and apply for postponement of the tax charged by the assessment, and
  • for extended time limits, also include the points below.

Extended time limits - additional points for explanation letter

If you are relying on HMRC’s ability to make an assessment under extended time limits, your explanation letter must also include

  • your explanation of why you consider that you are able to use extended time limits - the rules for extended time limits are at EM3270 for assessments made on or before 31 March 2010 and CH53100 for assessments made after 31 March 2010,
  • factsheet CC/FS9 if, exceptionally, you have not already issued it explain in your letter that factsheet CC/FS9 explains the taxpayers rights when we are considering penalties, and
  • a reminder that interest will arise on the eventual liability so the taxpayer should consider making a suitable payment on account.