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HMRC internal manual

Enquiry Manual

Partnerships: Approach to SA Enquiries: Partners' Review

When you are undertaking a full enquiry into a partnership you must review and include even minor and sleeping partners as they may be involved in any evasion or may be the unknowing means by which it is being achieved.

If you do not look at all the partners not only might you fail to identify or address all the risks of error or evasion, but settlement with one partner alone may seriously weaken or prejudice the HMRC position in relation to other partners in the firm if their affairs are later found not to be in order.

It follows that normally when you undertake a full enquiry into a partnership return you will also open separate Section 9A enquiries into the returns of each partner who was a member of the partnership during the return period.

If any of the partners has not filed his or her return by the time you have decided to open an enquiry consider making a determination EM2027 or take daily penalty action EM4570+.

If it is actually the partnership return you are waiting for consider instituting early forcing action by way of daily penalties under TMA70/S93A (3) EM4570+.