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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: CTSA - Manual Closure Notice

You should wherever possible issue a final closure notice through COTAX, see EM3870.

This guidance covers

The circumstances where you have to issue the final closure notice manually

The circumstances where you have to issue the final closure notice manually include where

  • an enquiry does not result in an amendment to the return, see COM71093 - steps 14 to 16,
  • 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,
  • your conclusions affect the company’s returns for other periods as well. In such cases you will have to make a manual amendment of the return as part of the final closure notice, see below, and make a separate amendment of the return for any other affected period using the Revenue Amendment function in COTAX, see EM3878,
  • there is a consequential impact on returns made by other companies, for example when an amount surrendered as group relief is reduced (see below).

As with final closure notices issued through COTAX it is important to be sure that you want to close the enquiry before proceeding, for example you wish to close the enquiry as a whole and not use a partial closure notice to conclude one or more matters, leaving the enquiry on-going.

What your manual final closure notice must include

Your manual final closure notice with Revenue amendment must:

  • say that you have completed your enquiry into the return
  • state your conclusions, taking into account any taxpayer amendment deferred under FA98/SCH18/PARA31(3) and any effect on other returns made by the company
  • if a taxpayer amendment was made during the enquiry and, exceptionally, you have not considered the amendment during your enquiry, say that you have not considered the amendment
  • say that the notice amends the return to give effect to your conclusions
  • give details of the amendments to the return in question, that is a full computation as it would appear on a COTAX issued final closure notice
  • tell the company that if it does not agree with the amendments that you have made to the company tax return it may appeal by notice in writing within 30 days after the amendments were notified to it, and
  • tell the company what it must do if the amendments affect returns made by any other company.

How to issue a manual final closure notice with Revenue amendment

If the enquiry results in an amendment to the return and you need to issue a final closure notice with Revenue amendment manually you should take the following steps. Make sure that all the steps are completed on the same day.

Step 1

Use MRSC (Maintain Rept / Realloc Signals (Company)) to inhibit reallocations or repayments to or from any AP of the company.

It is important to do this first or the next step will result in the lifting of repayment and reallocation inhibitions.

Step 2

Use MAPS (Maintain AP Signals) to enter as enquiry “Ended date” the date you issue your manual closure notice with Revenue amendment.

Step 3

In RAMA (Record Assessment/Amendment) use the option “Prepare a Revenue Amendment’ to enter the figures that reflect your conclusions. Do not go on to issue the Revenue amendment but instead store the amendment as a draft.

Step 4

Take a print out of the draft amendment and use the figures to help you prepare your manual closure notice with Revenue amendment.

Step 5

Prepare and issue your manual closure notice with Revenue amendment.

Step 6

In RAMA use the option “Prepare a Revenue Amendment’ to record the manual issue of a Revenue amendment in the figures contained in your earlier draft. You can do this by selecting ‘Record Manual Issue’ from the drop down menu for the ‘Do you want to?’ field on screen COT121G. Enter the date of issue as the date you issue the manual closure notice with Revenue amendment.

Amendments for other periods

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

Amendments affecting the returns of other companies

Where you amend an amount in a return which affects another company’s return, for example a reduction in an amount surrendered as group relief, the closure notice should include guidance on what the company needs to do about the original surrender, see EM8140.