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HMRC internal manual

Enquiry Manual

Concluding the Enquiry: SA Legislation: CTSA - Amounts to be Included in Closure Notices

The amendments you make in your partial or final closure notice will be the ones you would seek to uphold if there is to be a subsequent hearing of an appeal before the tribunal. They should neither overstate nor understate HMRC’s position, but should represent what are, in your view, the correct amounts. You should not use a larger figure than you feel is justified by the facts, simply to allow some ‘headroom’. But there is nothing to stop you stating in the notice what you consider to be the correct figures, and, following an appeal, later reach agreement for something less in response to further facts and considerations.

You should never make an amendment in amounts that do not accord with your conclusions. There is no scope for revising your conclusions because you subsequently consider matters covered in the enquiry were not adequately reflected in the partial or final closure notice.