Readers’ forum: Check confusion

In February 2020 our corporate client was informed by HMRC that they are subject to a ‘check of company tax return’ (FA 1998 Sch 18 para 24(1)) for the accounting period of 12 months to 31 March 2018. The return concerned was delivered to HMRC before the filing date so that in accordance with the same paragraph ‘notice of enquiry may be given at any time up to 12 months from the day on which the return was delivered’. In terms of ‘time limits’ the enquiry thus seems valid.

The same correspondence sets out the ‘scope of enquiry’ and states that it will include VAT (‘possibly going back up to four years’) and PAYE aspects – for the two tax years which fall into the corporation tax accounting period. I am concerned with the...