Closure Notices

A clear, practical, user-friendly guide to the law and practice relating to closure notices.

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About this work

When opening an enquiry, HMRC will usually raise questions about a tax return, and begin a dialogue with the taxpayer or any professional advisers.

An enquiry comes to an end with the issue by HMRC of a closure notice. Taxpayers who believe that an enquiry is being unreasonably prolonged may ask the tax tribunal to order HMRC to issue a closure notice. This is therefore a valuable taxpayer safeguard when correctly used.

In this book, the author examines the statutory rules and addresses the practicalities of the closure notice from the taxpayer’s point of view. In particular, the text examines how to obtain a notice and how to deal with it once it has been issued (including challenging the notice when appropriate).

The book complements other titles by the same author, including in particular Schedule 36 Notices, Tax Appeals and Taxpayer Safeguards, all available from Claritax Books.

Table of contents

• General information

• Introduction to closure notices

• Starting the enquiry process

• Seeking a closure notice

• What constitutes a closure notice?

• Challenging closure notices [expanded by way of example]
  • Appeals
  • The scope of any appeal – the place for alternative arguments
  • Consequential tax relief claims [expanded by way of example]
    • The usual time limit for making claims
    • Extension for consequential claims
    • Other claims, elections, etc.
    • Restrictions on extension for other claims
    • The limits of a tribunal’s powers on appeal

• Partial and final closure notices

• Other enquiries

• Partnership enquiries