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HMRC internal manual

Enquiry Manual

Concluding an Enquiry: SA Legislation: Figures used in Closure Notice

The figure you state in your partial or final closure notice will

  • be the total of all Tax and Class IV NIC liabilities (that are included in your amendment)
  • incorporate the amount shown in the original self assessment
  • be a single figure to reflect the fact that there is only one self assessment. You should explain how that figure is made up, by providing a computation, if it is not otherwise obvious.

Where you issue one or more partial closure notices your notice should state that this figure does not reflect the final position as your enquiry is not yet complete.

Where you have been unable to reach any agreement you should include in your notice the figures which represent your best view of the position which would obtain if all the points in dispute were settled in HMRC’s favour.

Where you have been able to agree some but not all of the points covered by your enquiry, your partial or final closure notice should include:

  • in respect of the agreed points, the figures which have been agreed, and
  • in respect of the points not agreed, your best view of the figures if all of the relevant points were to be determined in HMRC’s favour.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)

You should always seek amendments to the self assessment, however small, where they are in the taxpayers’ favour.

Where your enquiry relates to a claim or election in the return, having no immediate effect on the self assessment, you should normally seek to make the appropriate disallowance regardless of the amounts involved.

In any hearing of an appeal against an HMRC amendment before the tribunal, you should not normally argue for a figure higher than those stated in your partial or final closure notice, although you may put before the tribunal any evidence which would support a higher figure. The tribunal may decide to determine the appeal in a higher figure if they have evidence before them to indicate that HMRC’s amendment is inadequate.