MTT55170 - Administration: Compliance: Compliance checks: Closure notice

HMRC must issue a closure notice to the filing member at the end of every compliance check for each accounting period. The closure notice is issued in the form of a letter.

A compliance check is only finished when HMRC has issued the closure notice to the filing member of a group stating that the check is complete and that either:

  • no amendment is required, or
  • the return must be amended, as specified in the closure notice.

When it is issued, the closure notice takes effect. The compliance check is completed and, where HMRC has concluded that an amendment is required, the amendment is made.

Along with the notice, HMRC should provide the filing member with information supporting the conclusion reached.

This is set out in paragraphs 20 and 22, schedule 14 to Finance (No.2) Act 2023.

Partial closure notices

A partial closure notice may also be issued by HMRC. A partial closure notice allows HMRC to complete one or more of the matters being checked before fully completing the compliance check.

See CH279600 for guidance on partial closure notices.

Jeopardy amendments

See MTT55150 for guidance on closing a compliance check when a jeopardy amendment has been made.

Issuing a closure notice following amendment that has been deferred due to ongoing compliance check

See MTT55140 for guidance on how to close a compliance check when the filing member has amended a return within the time limits during an ongoing compliance check into that return.

Right of appeal

The filing member can appeal against a revenue amendment and the normal rules for appeals and postponement applications apply. It can then negotiate further, settle under Para 61 Sch 14 Finance (No.2) Act 2023, ask for a review, or notify the appeal to the Tribunal. See MTT55500+ for guidance on appeals and reviews.

Reissuing a closure notice

Reissuing a closure notice is not a routine procedure. HMRC will not do so unless there is a good reason to believe or accept that the original closure notice has not been received by the filing member of a group.

If a closure notice is returned undelivered, HMRC cannot reissue it until a new address for the filing member is entered on the group’s record.