HMRC internal manual

Enquiry Manual

Partnerships: Opening an Enquiry: Combined Notices

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.

You should not combine a notice of enquiry into a partnership return to the nominated partner with a notice under TMA70/S9A or a notification that Section 12AC(6) applies to his or her personal return. This is because under TMA70/S12AC (1) we are addressing the nominated partner in his or her capacity as the representative of the partnership, whereas under Section 9A or Section 12AC(6) we are dealing with his or her personal affairs.

Where the enquiries are not commenced at the same time you will need to issue to each partner a separate Section 9A notice and a copy of general information factsheet CC/FS1 (a or b) in respect of any actual enquiry and notification in respect of any deemed enquiry. But where you are undertaking a full enquiry, and simultaneously open enquiries into the partnership return under TMA70/S12AC and into each partner’s own return under Section 9A, or where you are undertaking aspect enquiries into both the partnership return and one or more of the partners’ returns you may combine the Section 9A notice and the notification of the deemed enquiry to each partner.