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HMRC internal manual

Enquiry Manual

Companies: Groups: Staged Risk Assessment

Normally you should undertake a full review of the company’s return before an enquiry is opened so that all risks are taken up at the same time. However there could be circumstances where you might not take up all risks concurrently, such as

  • an ongoing enquiry into an earlier return where the issue affects the current return
  • an issue affects more than one company in the group and it would not be appropriate to delay the enquiry
  • an early request for information that requires the opening of an enquiry into the return, for example in order to deal with an application from an overseas recipient to receive interest without deduction of tax.

Before requesting information in such circumstances you must always issue a notice of intention to enquire into the return. You should make it clear in the opening letter that you may be enquiring into other aspects in due course. In adopting this approach, you should take into account that the company may exercise its right to ask the tribunal to direct you to close your enquiry, see EM1975.

Provided you can explain why a delay in enquiry into(This content has been withheld because of exemptions in the Freedom of Information Act 2000) other aspects of the return to the company you should be able to demonstrate that you have reasonable grounds for not giving a closure notice until the proposed later enquiries are resolved.

You can request information at any time while an enquiry is still open, but the aim as far as possible should be to cover all risks that you have been able to identify at that time in the opening letter. This does not mean that you cannot request information after this time. Frequently the submission of information initially requested will give rise to further questions. You may need to extend the aspects covered in your enquiry to take account of information arising from returns submitted by other companies in the group. So long as the enquiry is still open you can request information which you consider necessary to check any aspect of the return.