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HMRC internal manual

Enquiry Manual

Partnerships: Discovery Provisions: Timing of Consequential Amendments


The consequential amendments to partners’ self assessments should normally be made as soon as the discovery amendment becomes final, as a result of either

  • the absence of an appeal against the amendment within the 30 day time limit, or
  • the determination of any appeal, either by agreement or by the tribunal.

You should not make selective amendments under Section 30B(2) for the purpose of bringing tax into charge on some partners but not on others.

The one exception to this is in the case of a deceased partner where the earlier time limit attaching to the Section 30B(2) amendment may mean that you will need to make an amendment to that partner’s self assessment to protect HMRC’s position EM7301.