Self Assessment: Enquiries into Returns
HMRC is entitled to enquire into the completeness and accuracy of any tax return. This right covers all enquiries, from straightforward requests for further information on individual items through to full reviews of books and records. All such enquiries require the issue of a formal notice.
Opening an Enquiry
SAV valuers are not directly responsible for the opening or control of any enquiry. It is the responsibility of the Inspector to ensure any enquiry is opened properly and is not closed until all necessary matters have been identified and settled. [See the Enquiry Manual EM3800 regarding closure of SA enquiries and Chapter 120 of this manual SVM120000 for its implications for SAV].
Once the time limit for making an enquiry has passed HMRC is unable to amend the taxpayer’s self assessment and HMRC can only make a further ‘discovery’ assessment if the taxpayer has been fraudulent or negligent or has made an incomplete disclosure of information.
An individual may request a formal review under the Tribunal rules. If you become aware of such an application that covers any valuation on which you are engaged, you should immediately refer the matter to the Litigation and Technical Advice Team (LTAT) who will arrange for the handling of the matter.
No unagreed valuation should be included in a notice of closure issued by the instructing office until the LTAT has been consulted - see Chapter 117 of this manual SVM117000.
When a formal notice of enquiry has been issued HMRC has additional powers to obtain information. See the Enquiry Manual EM2200 and Chapter 118 of this manual SVM118000.
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