CFM98770 - Interest restriction: administration: enquiry procedure: notice requiring SA amendment to prevent loss of tax during enquiry
TIOPA10/SCH7A/PARA45
It is possible that an HMRC officer may conclude that there may be a loss of tax to the Crown where a company tax return understates a company바카라 사이트™s tax liability in respect of a matter under enquiry in an interest restriction enquiry, unless the relevant company tax return is immediately amended. TIOPA10/SCH7A/PARA45 allows the officer to serve a notice in the company to require it to amend its self-assessment. This is analogous to the power under FA98/SCH18/PARA30 (often referred to as the 바카라 사이트śjeopardy assessment바카라 사이트ť procedures) in relation to company tax return enquiries.
The notice may be appealed, within 30 days. As in the case of a company tax enquiry, the HMRC review procedure in TMA70/S49A(2) may not be invoked in the event of such a notice.