Commentary

A6.402 Scope of a self assessment enquiry

Administration and compliance

A6.402 Scope of a self assessment enquiry

A6.402 Scope of a self assessment enquiry

There is no definition of an 'enquiry' in the legislation, but anything more than the correction of an obvious error in the return (within the nine month period for amendments, see A6.401) constitutes an enquiry and must be dealt with in accordance with the formal enquiry procedure. Note that a formal enquiry is distinct from a compliance check. For more on the difference between compliance checks and enquiries see A6.606.

Scope of enquiryCommentary
The legislation permits only one enquiry per return1.Once the time limit permitted for an enquiry has expired, or an enquiry has been concluded by way of a closure notice or contract settlement (see A6.420), HMRC cannot make any further enquiry into the same return. However HMRC can use the discovery provisions (see A6.701).
This does not apply if the return is subsequently amended because notice of enquiry can be given in respect of the amendment2.
The enquiry can extend to anything contained or required to be contained in the return3. This includes any claim or election. See also A6.401 and A4.202 for claims not included in returns.
In respect of an enquiry into a CTSA return an enquiry can extend to transfer pricing4, or double taxation relief5. It can extend to an amount included in the CTSA return that may affect either the company's tax liability for another period or the tax

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