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HMRC internal manual

Enquiry Manual

From
HM Revenue & Customs
Updated
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Partnerships: Opening an Enquiry: Non-Partnership Aspects Only

Where you issue a Section 9A notice to a represented partner and either you

  • have not previously issued, or
  • do not intend at this stage to issue

a notice under Section 12AC(1) opening a partnership enquiry you should use the following wording in your notice to the partner.

I am writing to tell you that I intend to make enquiries into your [20xx/xx.] return and have written to your agent (name) to ask for the information I need. These enquiries will cover only non-partnership aspects of your return. If I decide to make enquiries into any partnership aspects these will be undertaken with the partnership itself, but I will write to you to let you know if I do so.

I enclose a copy of our Code of Practice relating to enquiries. It explains how we make enquiries and how we keep our promise of fair treatment under HMRC’s Service Commitment to you.

When you have read the booklet [leaflet in aspect cases], please contact me if you require further information’

At the same time you should write to the agent as follows.

I have today issued to your client (name) a notice under TMA70/S9A of my intention to enquire into his/her [20xx/xx] return. A copy of the notice is attached’

If the partner is not represented your opening notice should read as follows.

I am writing to tell you that I intend to make enquiries into your [20xx/xx] return. These enquiries will cover only non-partnership aspects of your return. If I decide to make enquiries into any partnership aspects these will be undertaken with the partnership itself, but I will write to you to let you know if I do so.

I enclose a copy of our Code of Practice relating to enquiries. It explains how we make enquiries and how we keep our promise of fair treatment under HMRC’s Service Commitment to you.

When you have read the booklet [leaflet in aspect cases], please contact me if you require further information.