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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Completion applications - repeated applications

Some customers may make several completion applications during the course of an enquiry. How you deal with each application depends on the stage of the enquiry at which it is made. The only circumstance in which a completion application should not be processed as normal is where a further application is made immediately after the tribunal has rejected an earlier one (in effect, a protest against the direction). In these circumstances, you should tell the customer(s) that they have no grounds for making the application. If the customer(s) persists, you should explain the circumstances to the Tribunals Service, and leave it to them to decide whether they wish to consider the application again. If the rejection of a completion application is followed by Revenue delay, then any subsequent application should be processed normally, even if the circumstances have not altered since the earlier application was rejected.