There are a number of restrictions on the scope of an enquiry
Limits if there has already been an enquiry
Once an enquiry into a return has been closed, it can only be reopened under the ‘discovery’ provisions of TIOPA10/SCH7A/PARA42, see CFM98750.
If an enquiry has been closed, but a revised interest restriction return is subsequently submitted for the same worldwide group period of account, then the scope of an enquiry into a revised return (in the absence of a discovery) is restricted to the new information contained in the revised return – PARA43(5).
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