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Where Taxpayers and Advisers Meet

S9A enquiry with no request for information

Milbo
Posts:54
Joined:Wed Aug 06, 2008 4:07 pm
S9A enquiry with no request for information

Postby Milbo » Wed Feb 05, 2020 11:49 am

Towards the end of January, HMRC issued a S9A letter opening an enquiry into an individual's 2018 SATR which is clearly aimed at ensuring that the enquiry window wasn't firmly slammed shut.

Whilst I understand that the only condition that an officer of the Board must satisfy before commencing an enquiry is that they must give the taxpayer written notice of their intention to enquire into the tax return, it is the first time I have seen a S9A enquiry letter which states that they will not be asking any questions at this time.

Is this a new HMRC tactic (or one that I have been blissfully unaware of) that others have encountered?

Many thanks,

Mark

wamstax
Posts:2019
Joined:Wed Aug 06, 2008 3:39 pm
Location:Operate Nationally but based in Aberdeen
Contact:

Re: S9A enquiry with no request for information

Postby wamstax » Wed Feb 05, 2020 3:47 pm

Is the taxpayer under enquiry for another year or aspect ? If so they are only protecting their position so that they can raise matters under the protection of S9a after 31st Jan

Could be it is under review and would depend on the team concerned
regards and hope this helps
http://www.wamstaxltd.com
Operates Nationally with competitive costs
and email and phone contact (mob 07751720507) can be obtained from websites

Milbo
Posts:54
Joined:Wed Aug 06, 2008 4:07 pm

Re: S9A enquiry with no request for information

Postby Milbo » Wed Feb 05, 2020 4:00 pm

Hello Wamstax,

There are no ongoing enquiries into earlier years or any of the companies the individual is connected with.

My thought is that HMRC may be considering opening an enquiry into one of the companies but haven't gathered all they information they require as yet. Those companies have a May year end so HMRC would have until May 2020 to open an enquiry into the year ended 31 May 2018. Just a thought though.

Mark

wamstax
Posts:2019
Joined:Wed Aug 06, 2008 3:39 pm
Location:Operate Nationally but based in Aberdeen
Contact:

Re: S9A enquiry with no request for information

Postby wamstax » Wed Feb 05, 2020 8:55 pm

Of course it could have an earlier time limit for enquiry if the accounts were submitted earlier than the due date. A reason for sending in returns early for clients as HMRC may miss the "hidden" deadline of 12 months from submission.
regards and hope this helps
http://www.wamstaxltd.com
Operates Nationally with competitive costs
and email and phone contact (mob 07751720507) can be obtained from websites

Milbo
Posts:54
Joined:Wed Aug 06, 2008 4:07 pm

Re: S9A enquiry with no request for information

Postby Milbo » Thu Feb 06, 2020 10:26 am

Thanks again Wamstax, a good point.


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