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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Completion application - time by which enquiry decision notice must be given

The statute does not require the tribunal to specify the date by which the completion notice must be issued. But if the tribunal has concluded that you have no reasonable grounds for continuing with your enquiry, you should issue the enquiry decision notice as soon as possible, and in any event within 30 days of the date you receive notification of the tribunal’s determination. Once the tribunal has directed you to complete your enquiry, you must not attempt to obtain any further information from the customer(s) before making your enquiry decision. You can only base your decision on the information you already have (including third party and other information, such as local intelligence).

If the tribunal does specify the date by which you should issue your enquiry decision notice, you should comply with their direction.

You may still need to consider penalties after you have issued your enquiry decision notice. More guidance can be found in the chapter covering closing enquiries.