The SA 'enquiry' procedure makes it very important that we
maintain close liaison with Inspectors. It is also vital that
valuers fully understand the enquiry process outlined above.
Valuers need to be aware of the time limits set by the enquiry
timetable and, although conduct of an enquiry is the prime
responsibility of the Inspector, to ensure that full information
about the progress (or lack of progress) of a valuation and its
outcome is provided in good time.
Form CG30 reflects the requirements of SA. The form
indicates whether or not:
If a formal enquiry has
already been raised by the Inspector (e.g. on
other aspects of the return) you may decide what, if any, questions
need to be put to the taxpayer/agent and proceed in the normal way.
However such a case still needs to be subjected to Risk Assessment
(see Chapter 116 of this manual
SVM116000).
If the case comes under the SA regime but is not a
pre-filing request (and where the Inspector has
not already raised a formal enquiry), SAV needs to
consider whether the valuation offered may be accepted before
advising the Inspector to open a formal enquiry.
SAV should not encourage the unnecessary opening of formal
enquiries. Before we suggest the opening of a formal enquiry we
need to consider whether the valuation offered might be accepted on
the basis of the information available from internal sources (i.e.
the SAV file; the Companies House fiche; and the company tax
papers) and, of course, whatever information is provided by the
taxpayer in the tax return. The case should also be subjected to
Risk Assessment before a formal enquiry is requested.
Once it is clear that the value cannotbe accepted on the basis of the available information and a
worthwhile amount oftax is at stake, you should (except in PTVC cases where the
tax return has not yetbeen received) ask the Inspector to open an enquiry at
once.
Form VAL222 - which is available as a template on computer
- should be used forthis purpose. In PTVC cases, you can, of course, correspond
with thetaxpayer/agent straightaway but you should always bear in
mind the closure datefor the enquiry window (Enquiry Manual EM1506), which you
should prominentlynote in the relevant sub-file. If an enquiry has not
already been opened in a PTVCcase, you should aim to notify the Inspector of the need to
open one at the verylatest three months before the enquiry window closes. Even
where there is arequest for a PTVC, therefore, you must still ask for an
enquiry to be opened unlessnegotiations can be satisfactorily concluded before the
window period closes. Thisshould be done at the earliest possible opportunity in
order that SA informationpowers (Enquiry Manual EM2200 and Chapter 118 of this
manualSVM118000) can bebrought into play as necessary.
| Additional Guidance: SVM150000 |