Opening letter to a compliance check

Produced by Tolley in association with

Owner-Managed Businesses

Guidance

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The format of the opening letter

When HMRC issues a notice that it is checking a return, the opening letter will invariably request information and documents. The opening letter under TMA 1970, ss 9A, 12AC (for individuals and trustees, and partnerships respectively) or FA 1998, Sch 18, Pt IV, para 24 (for companies) is sent to the taxpayer or the director of the company, with a copy to the agent if the taxpayer or the company is represented. These letters will often be different in tone and content.

The opening letter to the agent will usually encourage an early phone call to discuss the check and enclose an information sheet asking about computer-based records. The opening letter to the taxpayer will not mention any of this but will explain what happens when the check has been completed. The format of the letter to the agent is typically a notification of the check followed by details of why the check is being made (see below ― note that these are both in

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