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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: Elements of partial and final SA Closure Notices

TMA70/S28A
TMA70/S28B
TMA70/SCH1A/PARA 7

Where you intend to issue a partial closure notice (see EM2163), your notice must

  • inform the taxpayer that you have completed your enquiries into the matter(s) to which the notice relates
  • inform the taxpayer that the notice does not constitute a final closure notice and your enquiry is ongoing
  • state your conclusions regarding the matter(s) to which the notice relates, including your conclusions about any claims or elections in relation to that matter that do not affect the self assessment
  • state that no amendment is needed or make the amendments required to give effect to your conclusions in relation to the matter(s).

Where you issue a final closure notice you must

  • inform the taxpayer that you have completed your enquiries, or in the event a partial closure notice was previously issued, that you have completed your enquiries into the remaining matter(s) that were not concluded by means of PCN(s).
  • state your conclusions, including your conclusions about any claims or elections that do not affect the self-assessment
  • state that no amendment is needed or make the amendments required to give effect to your conclusions.

The enquiry into any matter is completed when the relevant closure notice is issued to the taxpayer. A copy should be sent to the taxpayer’s agent.

If the taxpayer amended the return during your enquiry you will normally have included the amendment in your enquiry. If not, the taxpayer’s amendment takes effect when your closure notice is issued. In the event of a partial closure notice any taxpayer amendment will be restricted to those matters to which the notice relates or those matters affected by the amendment.

Where more than one officer has been involved in working the enquiry, the partial or final closure notice must always be issued by the case owner, see EM1535.