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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Companies: Groups: Opening Enquiries on More than One Company

Where an issue may affect the return of more than one company in a group, you must give notice of your intention to enquire into the return, or amendment to a return, for each company to be covered by your enquiries. Failure to give notice would prevent you from amending the self-assessment to give effect to an agreed adjustment. You must also send factsheet CC/FS1 to each company with its notice.

Normally you would open an enquiry into the returns of all of those companies that can be identified as being affected. If you do not know the identity of all of the companies which could be affected you will need to decide which returns to place under enquiry. You can either

  • give notice of intention to enquire into all of the returns which you believe will be affected by the matter, (this will normally be best practice), or
  • give notice of intention to enquire into one or more returns which you know will be affected and make arrangements to review the potential impact on other group companies at a later stage but before the time allowed by paragraph 24 to open an enquiry into those companies expires.

If you open an enquiry into a company’s return to deal with an issue which affects several companies in the group you should, wherever possible, cover all of the other aspects of that company’s return which merit enquiry at the same time.

Similarly, when finalising correspondence on an issue that affects more than one company, you will need to make it clear that any other enquiry issues in the cases affected remain open.