Requesting closure of a compliance check

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Guidance

At any time during the course of a compliance check, a taxpayer may apply to the Tribunal for a direction that HMRC should issue either a final or partial closure notice within a period specified by the Tribunal. See the Amendments to a return during a compliance check guidance note. See TMA 1970, ss 28A(4), 28B(5) for individuals and trustees, and for partnerships, respectively, and FA 1998, Sch 18, Part IV, para 33(1) for companies.

Note that this guidance note uses the term ‘compliance check’ in line with HMRC’s current terminology. However, the term ‘enquiry’ is still used in the referenced legislation.

Open compliance checks

An application for a partial or final closure notice will relate to formal compliance checks opened by HMRC under TMA 1970, s 9A (for individuals and trustees), TMA 1970, s 12AC (for partnerships) or FA 1998, Sch 18, Part IV, para 24 (for companies). Closure applications can only be made in relation to compliance checks opened using these formal powers.

An adviser should be mindful

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