Case report: deadline for issuing notice of HMRC enquiry clarified - In the case of Dock and Let Ltd v Revenue & Customs [2014] UKFTT 943 (TC), building services company Dock and Let filed its tax return for the period ended 31 March 2011 on 31 January 2012. On 31 January 2013, HMRC issued a notice of enquiry into the tax return.

Dock and Let’s tax advisers, Charterhouse (Accountants) LLP, argued that HMRC was out of time to enquire into the return as it understood the deadline for issuing the notice of enquiry to be 30 January 2012, ie, the 12-month period in which an enquiry could be opened included the date on which the return was delivered.