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HMRC internal manual

Claimant Compliance Manual

Opening and Working Enquiries: Completion applications following opening letter and request for information

Although customers have no right of appeal against a S19(1) notice of enquiry, they are entitled to ask the tribunal to direct that the enquiry should be completed at any time after the notice is issued. Some customers may want to apply for a completion notice immediately on receipt of the opening letter. In effect, any such application will amount to a challenge to your right to enquire into their entitlement and the amount of their award. If you meet this situation in practice you should not have any difficulty in showing that a direction is not appropriate. At this early stage of the enquiry it is unlikely that the customer(s) will have any real grounds for seeking a direction. If the customer(s) makes an application you should explain to them why an application is not appropriate at this point, and ask them to withdraw it. But if they pursue their application you should arrange for it to be referred to the tribunal at the earliest opportunity - see CCM12390