I would be interested to know the enquiry deadline for a CGT return made but no SATR required.
I understand that if a SATR is filed then the enquiry deadline for that return, and the disposal already reported would be contained in this, would be the usual 12 months from the date the TR is filed.
However if no TR is required I believe that it is assumed that a TR has been filed on the normal TR filing date, and therefore the equiry window is the LATER of:
12 months after the CGT return filed, and
12 months after the normal filing deadline
FA2019 Schedule 2 para 20(3)
As an example:
Filed CGT return 30/9/2020, no TR required, HMRC have until 31/1/2023 to open an enquiry.
Filed CGT return 30/9/2020, files TR 30/9/2021, HMRC has until 30/9/2022 to open an enquiry
The first example sees a lengthy enquiry window.
Do you agree the time limits are correct?