HMRC is entitled to enquire into the completeness and accuracy of any tax return. This right covers all enquiries, from straightforward requests for further information on individual items through to full reviews of books and records. All such enquiries require the issue of aformal notice.
SAV valuers are not directly responsible for the opening or
control of any enquiry. It is the responsibility of the Inspector
to ensure any enquiry is opened properly and is not closed until
all necessary matters have been identified and settled. [See the
Enquiry Manual EM3800 regarding closure of SA enquiries and Chapter
116 of this manual
SVM116000 for its implications for
SAV].
Once the time limit for making an enquiry has passed HMRC is
unable to amend the taxpayer's self assessment and HMRC can only
make a further 'discovery' assessment if the taxpayer has been
fraudulent or negligent or has made an incomplete disclosure of
information.
An individual may request a formal review under the new
Tribunal rules. If you become aware of such an application that
covers any valuation on which you are engaged, you should
immediately refer the matter to the Appeals Team who will arrange
for the handling of the matter.
No unagreed valuation should be included in a notice of
closure issued by the tax office until the Appeals Team has been
consulted – see Chapter 117 of this manual
SVM117000.
When a formal notice of enquiry has been issued HMRC has additional powers to obtain information. See the Enquiry Manual EM2200 and Chapter 118 of this manual SVM118000.
| Additional Guidance: SVM150000 |
