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HMRC internal manual

International Manual

Double Taxation Relief: Anti avoidance legislation: Discovery notices

Once the period in which an enquiry into a return may be made has elapsed or an enquiry has been closed, HMRC may issue a notice only if either:

  • the absence of a notice was due to deliberate conduct on the part of the person to whom the notice is issued, a person acting on their behalf, or their partner; or
  • HMRC could not have been reasonably expected to realise that a notice should have been issued on the basis of information supplied before the enquiry period lapsed.

In the above circumstances, HMRC may issue a notice and also a discovery assessment to give effect to the notice. The notice may be varied until the discovery assessment becomes final.