Unlike a compliance check, which focuses on specific items, a full enquiry gives HMRC the right to review your entire tax return and all supporting records. HMRC can open a full enquiry into any return within 12 months of the filing date, or within 12 months of the amendment date if you amended the return. Once opened, there is no restriction on which aspects HMRC can examine — income, expenses, capital transactions, and any other entries on the return are all within scope.
Full enquiries are more intensive and take longer to resolve than compliance checks. They typically run for 6 to 12 months, sometimes longer for complex cases involving multiple sources of income, property portfolios, or overseas interests. The process involves formal information requests, meetings with HMRC officers in some cases, and detailed negotiation on any adjustments and penalties.
HMRC will request bank statements, rental accounts, property transaction records, expense receipts, loan agreements, and business records. These requests are made under formal powers — Schedule 36 of the Finance Act 2008 gives HMRC the statutory right to issue information notices requiring you to produce documents and information. Non-compliance with an information notice can result in penalties of GBP300 initially, with daily penalties thereafter. Understanding these powers is important because it means the requests cannot simply be ignored — but it also means they must be proportionate and relevant.
One of the most important aspects of handling a full enquiry is managing its scope. HMRC may request information that goes beyond what is strictly relevant to the enquiry. We review every information request to ensure it is proportionate and within HMRC’s powers. Where requests are excessive or irrelevant, we push back formally. This is not about obstructing the enquiry — it is about ensuring it stays within its proper boundaries and does not expand into a fishing expedition.
We take over all correspondence with HMRC from the date we are formally appointed as your agent. We review your records, identify any areas of exposure before HMRC finds them, prepare all responses to information requests, attend meetings with HMRC if required, negotiate on any adjustments and penalties, and manage the enquiry to the fastest resolution the facts support. You deal with us. We deal with HMRC.
Full enquiries typically take 6 to 12 months to resolve. Complex cases involving multiple properties, overseas income, or business activities can take longer. We provide a fee estimate at the outset based on the likely scope and complexity, and we update the estimate as the enquiry develops. If you have tax investigation insurance (often included in fee protection policies from your existing accountant), our fees may be covered. We advise on whether your policy applies and manage the insurance claim if so.
Book a free 30-minute consultation to discuss your property tax position with a specialist accountant.
