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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: Elements of CTSA Closure Notices

FA98/SCH18/PARA 32
FA98/SCH18/PARA 34

Where you intend to issue a partial closure notice (see EM2160) your notice must

  • inform the company 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, and
  • where appropriate, make any amendment of the return to give effect to your conclusions.

Where you issue a final closure notice you must

  • inform the company that you have completed your enquiry, 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, and
  • where appropriate, make the amendment of the return to give effect to your conclusions.

Your conclusions must cover all matters, including

  • those which may have been worked outside your office by, for example, Business International or Specialist Investigations, and
  • the effect on the company’s returns for other periods.

It is very important that any impact on the company’s returns for other periods is included in the stated conclusions. You can only amend the returns for those other periods ‘to give effect to the conclusions stated in the partial or final closure notice’. If you fail to include such conclusions in your closure notice you may find yourself unable to amend the liability for those other periods.

Although a closure notice that states any conclusions affecting other returns must include an amendment of the return enquired into, it should not include amendments of those other returns. You must separately amend those other returns, using the Revenue Amendment function in COTAX, to give effect to your conclusions.

You must issue a copy of the closure notice and any other amendment to the company’s appointed agent if it has one.

The normal procedures for appeals and postponements will apply, see ARTG2120+.

Where your conclusions and amendments have a consequential impact on the returns of other companies, for example where an amount surrendered as group relief is reduced, see EM8130.

Detailed guidance follows at EM3870+.