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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: Further Information

Once you have issued a final closure notice it normally means that you cannot seek any further information about the return or in the case of a partial closure notice, further information about the matter(s) to which the notice relates. However, if the taxpayer requests a review of the case the reviewing officer may ask for additional information. If the taxpayer notifies their appeal against an HMRC amendment to the tribunal, either you or the tribunal may consider that the taxpayer ought to produce further information in support of arguments advanced at the hearing. For more detailed information refer to the Appeals, Reviews and Tribunals Guidance (ARTG).

These circumstances might arise for example where there has been an enforced early completion of an enquiry following a tribunal direction and, based on the limited information which was available, you have amended the taxpayer’s self assessment to a higher figure with which he or she disagrees.

However, you must ensure that this is not interpreted as a means of continuing an enquiry which has been formally completed. You must avoid in particular the appearance of re-opening enquiries which have been completed following a tribunal direction.