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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Partnerships: Company Partners


Enquiries into the returns of partnerships which include one or more companies as partners will be made under the SA rules, whether before or after the introduction of CTSA.

For CTSA periods there is deemed to be an enquiry under FA98/Sch18/Para 24 on the company.

However, prior to the introduction of CTSA the deeming provision had no effect on partners who were companies.

Where your enquiries extend to a company member of a partnership pre-CTSA you will be required to state your reasons for dissatisfaction with the company’s return. To the extent that your enquiry is limited to partnership issues it should be sufficient to say that you cannot agree the company return until your enquiries into the partnership return are concluded. If your dissatisfaction relates also to non-partnership issues you should explain the reasons for your dissatisfaction and provide the taxpayer company or its agent with an opportunity to respond to those reasons.

For pre-CTSA periods TMA70/S28B (4) cannot apply to company members of a partnership. Partnership enquiries involving corporate members will be undertaken at partnership level, but the consequences of the enquiry will need to be reflected in amended assessments or further assessments on the company as appropriate.

The normal assessing time limits continue to apply.