We successfully defended against a Loan Charge enquiry. We amended an 18/19 return, the enquiry window for which shut on 31st October 2021. HMRC sent us and our client a letter dated 29th October 2021. Our client was preparing to send the information requested, believing it was within the time limits.

However it is very important to note that not only must the enquiry be opened by the deadline, the client must have received it by this date. We could show that the client had not received it by 31st October 2021, and therefore the enquiry was out of time.

Oh, and it only took HMRC almost exactly a year to get back to us.