We have had a couple of cases lately where HMRC has issued enquiry notices which are out of date. This has been challenged at our instigation and HMRC has backed down. However, it shows the need for accountants to check the very basis upon which HMRC in launching enquiries in all cases. “is the enquiry within the enquiry window?” should be one of the first questions. It is worth remembering it is not just the date of issue of the enquiry letter that is relevant so much as the date of receipt. In one case the letter was dated 5 days before the enquiry window closed but did not arrive until 5 days after. HMRC has now conceded they can not proceed with the enquiry.
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