This is normally the first type of notice you will consider issuing. It is issued to the person whose tax position you are checking.
You do not need to get authorised officer agreement before issuing a customer notice. However in certain circumstances you may wish to get approval from the First-tier Tribunal.
There are special rules when a SA, CTSA or Land transaction return has been made, or in the case of a partnership.
When a person has made a self assessment return or a Corporation tax self assessment return for a chargeable period, a notice can only be given for that period if one or more of the following are satisfied.
A. there is an open enquiry into the return or a claim relating to the tax in the return.
B. you have reason to suspect
- tax may not have been assessed
- tax may have been under assessed, or
- excessive relief has been given, and
- you will be able to make a discovery assessment or determination.