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HMRC internal manual

Self Assessment: the legal framework

HM Revenue & Customs
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Enquiries into Tax Returns: referrals to the tribunal during an enquiry

HMRC and the taxpayer can jointly refer an issue that is the subject of an open enquiry for determination by the tribunal during the enquiry

Sections 28ZA to 28ZE

In most cases a contentious issue that arises within an enquiry can be dealt with through the appeal procedures at the end of the enquiry. But where both HMRC and the taxpayer want a particular issue determined by the tribunal before an enquiry is completed, they can refer the matter together to the tribunal. The matter will be heard and determined by the tribunal in the same way as an appeal and the determination is binding on the parties. It will be taken into account in the enquiry closure notice (see SALF407).