Taxes Management Act 1970 section 12AC

Notice of enquiry

Section 12AC sets out the rules governing when and how HMRC may open an enquiry into a partnership return, including the time limits for doing so and the scope of any such enquiry.

• HMRC may enquire into a partnership return by giving notice to the partner who submitted it (or their successor) within specified time limits.
• The time allowed depends on whether the return was filed on time, late, subsequently amended, or subject to a dispute referral — and is calculated by reference to quarter days (31 January, 30 April, 31 July and 31 October).
• A return already subject to an enquiry cannot generally be enquired into again, unless the return has been amended or a dispute has been referred, and in those cases the scope of the new enquiry is limited to the matters affected.
• Opening an enquiry into the partnership return automatically triggers an enquiry into each individual partner's personal, trustee or company tax return.