HMRC compliance checks, enquiries and discovery assessments

The following Tax practice note provides comprehensive and up to date legal information covering:

  • HMRC compliance checks, enquiries and discovery assessments
  • Compliance checks
  • Pre-return checks
  • Enquiries into tax returns
  • Partnerships
  • Voluntary tax returns
  • The enquiry window
  • Closure of enquiries
  • Amending the tax return upon closure of the enquiry
  • Closures notices relating to partnership tax returns
  • More...

HMRC compliance checks, enquiries and discovery assessments

There are various options open to HMRC when it suspects that tax has not been paid, or has been underpaid. These include:

  1. issuing a determination—this is relevant where a taxpayer fails to file a return for corporation tax, income tax or capital gains tax (CGT) and is based on an estimate by HMRC of the tax due (for more information, see Practice Note: What is a tax determination?)

  2. carrying out a compliance check—this may be a formal enquiry into a tax return, but can also mean a range of possible actions by HMRC either before or after a return is submitted

  3. issuing a discovery assessment—this is mainly relevant where HMRC has discovered (perhaps as a result of a compliance check) that a return of corporation tax, income tax or CGT is wrong, but the enquiry time limits for that return have passed, or an enquiry has already been made but is now closed

  4. if VAT has been underpaid, or no VAT return has been submitted, HMRC can issue a VAT assessment (for more information, see Practice Note: VAT assessments)

Revenue Scotland and the Welsh Revenue Authority have equivalent powers in relation to the devolved taxes.

This Practice Note is primarily about HMRC compliance checks, enquiries and discovery in relation to income tax, CGT and corporation tax. Similar provisions appear in

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