A consultation proposing changes to the above rules has now been opened. Responses should be submitted by 12 March 2015.

The Government proposes to enable HMRC to refer matters to Tribunal with a view to achieving early resolution of one or more aspects of an enquiry into a tax return. Views are being sought on this proposal to reflect the complex nature of contemporary tax affairs and to modernise the administration of the tax system by increasing flexibility. The proposed changes would affect the Self-Assessment enquiry framework in respect of Income Tax, National Insurance Contributions (including Class 2 and 4 in certain circumstances), Capital Gains Tax and Corporation Tax.