SCHEDULE 4... CSOP schemes
F1PART 7Notification of schemes, annual returns and enquiries
Enquiries
28F
(1)
This paragraph applies if notice is given in relation to a CSOP scheme under paragraph 28A.
(2)
HMRC may enquire into the scheme if HMRC give notice to the scheme organiser of HMRC's intention to do so no later than—
(a)
6 July in the tax year following that in which the initial notification deadline falls, or
(b)
if the notice under paragraph 28A is given after the initial notification deadline, 6 July in the second tax year following the relevant tax year.
(3)
HMRC may enquire into the scheme if HMRC give notice to the scheme organiser of HMRC's intention to do so no later than 12 months after the date on which a declaration within paragraph 28B(7) is given to HMRC.
(4)
Sub-paragraph (5) applies if (at any time) HMRC have reasonable grounds for believing that requirements of Parts 2 to 6 of this Schedule—
(a)
are not met in relation to the scheme, or
(b)
have not been met in relation to the scheme.
(5)
HMRC may enquire into the scheme if HMRC give notice to the scheme organiser of HMRC's intention to do so.
(6)
Notice may be given, and an enquiry may be conducted, under sub-paragraph (2), (3) or (5) even though the termination condition is met in relation to the scheme.