CFM98740 | Interest restriction: administration: enquiry procedure: normal time limits for opening an enquiry

TIOPA10/SCH7A/PARA41

This guidance has effect for periods of account beginning on or after 1 April 2023. For earlier periods, HMRC staff should contact the CIR team within BAI Financial Products for guidance.

The time limits for opening an enquiry reflect the long period of time in which a reporting company may submit a revised interest restriction return - normally 36 months after the end of the period of account - TIOPA10/SCH7A/PARA8(3)(a). Accordingly the “normal” time limit for opening an enquiry is slightly longer, 39 months (PARA41(2)(a)).

It is possible that the submitted return contains estimated information (PARA27). Tying in with the enquiry deadline, the reporting company must inform HMRC within 30 days if this remains the case 36 months after the end of the period of account.

An enquiry may also be opened later than the 39 month point if this is before the end of 31 January, 30 April, 31 July or 31 October following the first anniversary of HMRC receiving a return or revised return (this is analogous to the limit in FA98/SCH18/PARA24(4)).