The window for HMRC to make enquiries into company tax returns is changing as a result of a recommendation made by Lord Carter of Coles in his March 2006 'Review of HMRC Online Services'.
FA 2007 s 96(3) (4) and (6) changed the period during which HMRC can give notice of enquiry into a company tax return. The change applies to returns for accounting periods ending after 31 March 2008 and is designed to give earlier certainty to companies that file early. For accounting periods ending on or before 31 March 2008 the enquiry window for returns filed on time closes 12 months from the statutory filing date.
For accounting periods ending after 31 March 2008 the enquiry window for most returns delivered by the filing date will close 12 months from the day on which HMRC receives the return. For example if a return...
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