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HMRC internal manual

Technical Teams Operational Guidance

Settling the enquiry: agreeing income profit additions: the starting point

Where the disclosure in the Disclosure Report is broadly accepted the starting point is the schedules to the Report itself. In non-report cases the starting point is usually the taxpayer’s returned income or profits.

In some cases (ghosts, failure to notify cases etc.) there may be no return or at least no return of the matter which is the subject of investigation. In these cases the starting point will be the Investigator’s own schedules derived from investigation.

Where the registration is concerned with a single issue or transaction there may be no need for ‘schedules’ as such at all.