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Introduction

An important clarification needs to be made to help in the understanding of this note. Whilst the legislation refers to an ‘enquiry’, HMRC now refers to enquiries as ‘compliance checks’.

As this note specifically covers HMRC’s powers, the term enquiry has been used to match up with the language used in the legislation. However, some of the other material referred to, such as factsheets, includes the term compliance checks rather than enquiry.

For the purpose of this note, an enquiry and a compliance check have the same meaning.

An HMRC Officer has the power to either correct a return or open an enquiry, and each of these processes is discussed below.

For more details about compliance checks, see the Types of checks on returns guidance note. For details of what to do when a compliance check is opened, see the Opening letter to a compliance check guidance note and other guidance notes in that subtopic.

Note that HMRC’s enquiry powers are the subject of a wide-ranging