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HMRC internal manual

Enquiry Manual

Reopening Earlier Years: Assessments: Notification to Taxpayer

Where you make an assessment for the purposes of making good a loss of tax/NIC, you must issue an explanation letter at the same time, see ARTG2190. Details of what to include in the letter are explained below.

SAM20061 explains the procedure for issuing the assessment and which SEES letters to use.

Explanation letter

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.

You should also explain under which legislation the assessment is being issued, for example section 29 TMA 1970.

If you are making an extended time limits assessment, your explanation letter must also include

  • your explanation of why you consider that you can 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,
  • a reminder that interest will be charged when tax is paid late,
  • if you are considering or intend to charge penalties, you should also include a copy of factsheet CC/FS9 if you have not previously sent one and explain in your letter that CC/FS9 tells the person about their rights when we are considering penalties.