Commentary

A6.413 Amendments to the return during an enquiry

Administration and compliance

A6.413 Amendments to the return during an enquiry

A6.413 Amendments to the return during an enquiry

Amendment by the taxpayer

Where a notice has been given of an intention to enquire into a return, the taxpayer has a statutory right to amend his self-assessment during the enquiry (see A6.401). The same applies after the taxpayer receives a follower notice which requires amendment of a tax return following litigation of a representative case challenging a tax avoidance scheme (see A6.401 and A7.247)1.

Such an amendment does not affect the amount of the self-assessment included in the return, but any taxpayer amendment that relates to any matters in an open enquiry may be concluded by a partial or final closure notice (see A6.418A). Prior to 16 November 2017 the amendment could not take effect until the closure notice was issued.

The amendment will not take effect if the HMRC officer either decides that it is incorrect or takes it into account in formulating the liability in the partial or final closure notice. Furthermore, such an amendment does not limit the

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