Opening and Working Enquiries: SA completion applications
If either or both of the customers are also SA taxpayers, and an enquiry has been opened into either or both of their SA returns, they will have the right to apply to the First-tier Tribunal - Tax Chamber (Prior to 1 April 2009 this was the General Commissioners) for a direction that the enquiries into their SA return(s) should be completed.
If you are working an NTC enquiry into a year for which there is also an open SA enquiry, you should already be liasing closely with the person responsible for carrying out the SA enquiry or enquiries. You should therefore be made aware of any applications made by the customer(s) for a direction to complete the SA return. If the First-tier Tribunal - Tax Chamber directs that the SA enquiry should be completed the closure of the enquiry will automatically close the window for opening an NTC enquiry.
If you have already opened an NTC enquiry the customer might apply under S19(10) to the Tribunals Service for them to direct that the NTC enquiry is completed. If they make such a request, see the guidance at CCM12300.
If you are aware that the customer has made similar request to both the First-tier Tribunal - Tax Chamber and to the Tribunals Service you will need to co-ordinate the action but it is possible for the two tribunals to reach different conclusions.