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HMRC internal manual

Claimant Compliance Manual

HM Revenue & Customs
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Opening and Working Enquiries: Completion applications - following issue of formal notice

The formal notices which may lead to completion applications include

  • a formal S19(2)(a) notice for information
  • a penalty notice for failure to provide information.

In addition, formal notices issued in the course of an examination into a more recent year, or an enquiry into an earlier year, may trigger a completion application. These notices include

  • formal notice for information under Ss14(2), 15(2), 16(3)
  • a decision under S14(1) on the entitlement / amount of the award
  • a decision under S15(1) on a CoC
  • a decision under S16(1) to amend or terminate the award
  • an enquiry notice under S19(1)
  • a discovery decision under S20(1).

If the customer(s) makes an application at any of these points you should explain the appropriate rights of appeal against whatever formal notice has been issued. You should suggest to the customer(s) that it would be better to follow this route than to pursue the application, particularly where the year involved is a later or earlier one. (But note that no appeal right exists against an information notice under Ss19(2), 14(2), 15(2) and 16(3).) If the customer(s) persists in the application where any of these notices is involved, you should arrange for it to be referred to the tribunal at the earliest opportunity - see CCM12390.

A completion application cannot be made in respect of an examination. If you have both an open examination and an enquiry, and the tribunal directs you to close the enquiry, your examination will remain open unless you decide to close it.