Taxes Management Act 1970 section 12ZM

Notice of enquiry

Section 12ZM establishes HMRC's power to open an enquiry into a tax return by issuing a notice to the taxpayer, and sets out the time limits within which such a notice must be given.

• HMRC may enquire into a tax return by giving written notice to the taxpayer.
• The notice must be issued within a specified time limit, generally within twelve months of the filing date or the date the return was actually submitted, whichever is later.
• Only one enquiry may be opened into a return, unless the return has been amended, in which case a further enquiry may be opened into the amendment.
• The taxpayer does not need to have done anything wrong for HMRC to open an enquiry — it can be a routine check or a targeted investigation.