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HMRC internal manual

Enquiry Manual

Companies: Enquiries into Directors and Participators: Closure Applications

The procedures which allow individuals and companies to apply separately to the tribunal for the enquiry into their own return be completed means you need to make sure the company and linked director enquiries are worked together. At each stage you should evaluate whether you have all the information you need in respect of all the linked enquiries.

When faced with a completion application you will need to demonstrate a clear link between the company and director(s) enquiries. You therefore must have a clear understanding of the purpose of your enquiries into the directors’ returns and how these link to the tax affairs of the company. You may explain to the tribunal why the enquiries are interlinked, but you should still respect each taxpayers right to confidentiality as far as you can EM1995.