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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 the time limits for raising a discovery assessment. For the internal HMRC guidance provided to officers on the raising of 'extended time limit' discovery assessments (ie those outside of the normal four-year time limit), see EM3257.

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.

More detailed information about time limits can be found at A4.320.