Commentary

A6.304 Discovery and power to make determinations

Administration and compliance

A6.304 Discovery and power to make determinations

A6.304 Discovery and power to make determinations

Discovery

The term 'discovery' refers to HMRC's right to re-open earlier chargeable periods, which are regarded as final and conclusive, by way of further assessment.

Under self-assessment, once the 'enquiry window' (see A6.401) has closed or an enquiry has been finalised by means of a closure notice, the only way that HMRC can bring further profits into charge is by the use of the discovery provisions1 (see Division A6.7).

Determinations

HMRC may make a determination of tax due under the following circumstances:

  1.  

    •     where a return which has been required under TMA 1970, s 8

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