HMRC enquiry deadlines/windows

Could HMRC get a second bite of the cherry?

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Are there circumstances when HMRC can revisit a earlier tax return enquiry which has been settled and is now out of time?  I'm thinking about a situation where a later 2014-15 enquiry uncovers something that 'might' have a bearing on a 2011-12 enquiry which was settled. 

The later enquiry may have unearthed an issue in relation to the ER 5% test and preference shares not qualifying.  Although a similar shareholding arrangement may have been in place in the earlier year, this wasn't queried at the time HMRC made their enquiries, but could they re-open the earlier year if they now believe something similar may have occurred?

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By Portia Nina Levin
18th Jan 2017 15:20

If they are out of time to enquire, they are out of time to enquire.

They can raise a discovery assessment though, and you would then need to deal with the issue if you wanted to appeal.

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