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HMRC internal manual

Enquiry Manual

Working the Enquiry: partial closure notices: taxpayer’s right to request a partial closure notice

The legislation also includes the right for the taxpayer to apply to the tribunal for a direction requiring an officer of the Board to issue a partial closure notice within a specified period.

This mirrors the existing right for the taxpayer to apply to the tribunal for a direction requiring an officer of the Board to issue a final closure notice within a specified period.

Taxpayers may also request HMRC issue a partial closure notice by consent which will be a decision made operationally and agreed (or not) by the authorising officer.

EM2161 explains that HMRC policy is that PCNs are only issued by HMRC in serious or large cases however even if it is not a serious or large case the taxpayer still has the right to request a partial closure notice.