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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Partnerships: Discovery Provisions: Appeals


The taxpayer can notify the appeal against the discovery assessment to the tribunal before you have settled your enquiry into the partnership. Determination of that appeal may settle the amount of the liability arising from the partner’s non-partnership sources of income. But that does not mean that you are prevented from later bringing further tax into charge as a result of settling the partnership appeals, as a separate matter, and making the consequential amendments to each partners’ self assessment(s)

The only effect of the earlier determination of an appeal against a discovery assessment on a partner for the same year is that the quantum of the adjustment ultimately made under Section 30B(2) `to give effect to the amendments of the partnership statement’ will have to take account of the amount of tax finally charged in the discovery assessment.