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HMRC internal manual

Enquiry Manual

Companies: Enquiries into Directors and Participators: Opening Linked Enquiries

Where you plan to open, or have opened, an enquiry into a company, you need to decide whether, and at what stage, to open linked enquiries into the personal return(s) of any director or participator. Your decision depends on the particular circumstances of each case. If there is no open enquiry on a director or participator and that director’s or participator’s return presents clear risks of its own you will normally open a linked enquiry into the relevant personal return(s).

You must issue a separate enquiry notice to each director whose return you need to make enquiries into. You should also issue factsheet CC/FS1 to each.

You need to be in control of the progress of all linked enquiries. This reduces the risk of enquiries being closed prematurely, which would prejudice the result of your enquiries into the company.

You should normally take ownership of any linked enquiries into directors’ returns. This includes any enquiries that are already open. Make sure that you contact the case owners for the personal returns.

Your enquiry into a director’s return must cover all the risks present in that return and not just those relevant to your company enquiry. Normally you will achieve this by teamworking with officers who have particular knowledge of the director’s tax affairs, or expertise in personal taxation. As owner of the company enquiry you must make sure that all the linked enquiries are co-ordinated.