The officer will always have to consider whether or not it is appropriate to open a formal enquiry before starting a compliance check.

If the compliance check is to be made into VAT or PAYE/CIS, the officer will not need to open an enquiry before making the check, even if the taxpayer’s income tax or corporation tax position is to be checked at the same time.

If the aim of the compliance check is to renew records relating to the taxpayer’s income tax or corporation tax position, and the risk is within an open enquiry window, the officer must issue an enquiry notice if one has not been issued already.

If the officer has identified a risk for a period for which an enquiry window has closed and either the risk is unlikely to affect other years or the risk cannot be identified by checking the current period or a period for which the enquiry window is still open, consideration will have to be given as to whether a discovery assessment can be made.  This might arise in the situation where a capital gain had not been assessed.

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