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The discovery provisions allow an HMRC officer to make an assessment to recover a loss of tax where certain conditions are met¹. A discovery assessment is often used if the time limit to open an enquiry into the matter has passed. For details of the conditions, see A6.703.

The commentary below discusses where the discovery relates to a matter incorrectly reported on a tax return due to careless or deliberate behaviour. The categorisation of the taxpayer's behaviour is important because it affects the number of years that HMRC can go back to raise the assessment². See A6.711.

Note that the commentary below refers only to the legislation as it applies to individuals, but unless otherwise stated, it can be assumed that it also applies to partnerships and companies. For specific commentary on discovery for partnerships and companies, see A6.715 and A6.716 respectively.