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HMRC internal manual

COTAX Manual

Enquiries: CTSA enquiries: Partial closure notice (Action Guide)

To make a partial closure notice involving any CTSA AP, consider steps 1 – 12 below.

Action Steps
Partial Closure Notice will result in a repayment Steps 1 - 2
Partial Closure Notice will result in Additional tax due Steps 3 - 10
Partial Closure Notice will result in No additional tax due Steps 11 - 12

 

Repayment

  1. If the Partial Closure Notice will result in a repayment then go to COM71030 and follow the ‘Repayment during enquiry’ guidance.

Existing assessments and penalty determinations

  1. Leave undisturbed any assessments, including self assessments and late filing penalties on the COTAX record for relevant APs. Do not make any new ones.

Additional tax due {#}

  1. Where the Partial Closure Notice results in additional tax being due calculate the additional liability on the aspect being closed, exclude any credit, debit, late and repayment interest along with any penalties under Schedule 24 or 18 and deal with these separately. See EM6050 and EM5250 for guidance.

  2. For companies subject to the QIPs, the calculation of any credit and/or debit interest will be calculated when the enquiry is fully closed in COTAX or included in the contract settlement.

  3. Complete the SAFE-PCN SEES template including only the tax charging using the charge type ’Tax on Company Assessed’ and  in the other reference field, enter “Para 32/34 Sch18 FA 1998” as per the SAFE charge matrix.

  4. Consider whether penalties are appropriate and if so raise separate charges in SAFE.

  5. Send the SAFE stencil to your local SAFE user to raise the charge.

  6. Prepare a ‘Partial Closure Notice’ for issue to the company/agent after the appropriate authorisation has been obtained. See CH279600 for guidance.

  7. Use Function NOTE and record a details of the PCN issued. Update CaseFlow/CRMM notes where the PCN has resulted in an additional amount of tax due.

  8. Once the SAFE charge has been raised update COTAX, CaseFlow/CRMM notes with the charge reference.

No additional tax due {#}

  1. Prepare a ‘Partial Closure Notice’ for issue to the company/agent after the appropriate authorisation has been obtained. See CH279600 for guidance.

  2. Use Function NOTE and record a details of the PCN issued.