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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: CTSA - Form of Closure Notice

FA98/SCH18/PARA 32

FA98/SCH18/PARA 34 {#IDAVVPLH}

Where you 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 company 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 the 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 one or more partial closure notices were previously issued, that you have completed your remaining enquiries
  • state your conclusions, and
  • where appropriate, make the amendment of the return to give effect to your conclusions.

Your statement of conclusions should always contain sufficient detail to enable the company to understand all amendments you make to its returns, including any you have to make for other periods.

Final closure notices

Where an enquiry results in an amendment to the return, you should, wherever possible, issue the final closure notice through COTAX by using function ‘Prepare a closure notice with Rev Amdt’ within the Record/Amend assessment function (RAMA). The computer will issue the notice to the company with messages explaining that this is the formal closure notice and that it reflects HMRC’s conclusions.

Where the enquiry results in an amendment to the return but it is not appropriate or practicable to issue the final closure notice through COTAX, for example where the standard wording and free-format space in the RAMA function are inadequate or your conclusions affect the company’s returns for other periods or the returns of other companies, you will have to issue a manual closure notice and amendment, see EM3871.

You will need to make any amendment to the company’s return for any other period by separate notice, see EM3878.

Where an enquiry does not result in an amendment to the return, you will have to issue the closure notice manually - see COM71093 - steps 14 to 16. You can use the standard format letter CTSA23 available in Excel SEES Forms & Letters.