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HMRC internal manual

Specialist Investigations Operational Guidance

Information and inspection powers: Schedule 36 FA 2008: taxpayer information notices after assessments or closure notices have been issued - avoiding premature action

The best way to avoid being prevented from issuing a taxpayer notice by the conditions in paragraph 21 Sch 36 FA 2008 is to avoid the unnecessary premature use of closure notices or protective assessments.

You should be very cautious about using these methods to force information. Information powers, backed up by penalties, should be used to obtain information. Assessment and closure should be used when you have all the information you need.

Sometimes it will be impossible to avoid issuing closure notices or protective assessments before you are quite ready. You may be obliged to issue a closure notice by the tribunal, following an application by the taxpayer. Or the expiry of assessing time limits may force you to raise protective assessments. In these circumstances, you should try to issue any necessary taxpayer notices before issuing the assessment or closure notice.