Taxes Management Act 1970 section 9A

Notice of enquiry

Section 9A sets out the rules governing when and how HMRC may open a formal enquiry into an individual's or trustee's self-assessment tax return, including the time limits for doing so and the scope of such an enquiry.

• HMRC may open an enquiry into a personal or trustee tax return by issuing a notice of enquiry to the taxpayer within strict time limits
• If the return was filed on time, HMRC has 12 months from the date the return was delivered; if filed late, the deadline extends to the next quarter day after the first anniversary of delivery
• A return may generally only be subject to one enquiry, but a further enquiry is permitted if the taxpayer subsequently amends the return — in which case the new enquiry is limited to matters relating to that amendment
• The scope of an enquiry can extend to anything in or required to be in the return, including claims and elections, as well as consideration of transfer pricing notices and counteraction notices for schemes designed to increase double taxation relief