Commentary

A6.418A Full or partial closure notices issued by HMRC or requested by a taxpayer

Administration and compliance

A6.418A Full or partial closure notices issued by HMRC or requested by a taxpayer

Closing a self assessment enquiry

A6.418A Full or partial closure notices issued by HMRC or requested by a taxpayer

Enquiries may be settled by:

  1.  

    •     formal closure notice, or

  2.  

    •     deed, see A6.419A, or

  3.  

    •     contract settlement, see A6.420

Full and partial closure notices

The issue of a closure notice means that HMRC gives written notification of the closure of the enquiry and makes any adjustments it considers to be necessary (see A6.420)1. The HMRC officer will state his conclusions regarding any omissions or understatement of income, gains or business profits he considers to have occurred, and the amount of additional tax due in respect of those omissions or understatements. Such a statement is on a 'without prejudice' basis so that if the conclusions are not agreed, HMRC is not bound by them in any subsequent proceedings2.

This applies to company3 individual or trustee4 and partnership5 returns.

For more on the form and validity of closure notices see A6.418B.

Types of closure noticeCommentary
Partial closure noticeA partial closure notice closes a particular aspect of an enquiry and it is distinct from a full closure notice6. Any particular matter to which an enquiry relates is completed when an officer informs the company by a partial closure notice that he has completed his enquiries into that matter. An enquiry into other matters may remain open.
The partial closure notice gives certainty to the taxpayer, whilst at the same time enabling earlier collection of any tax due on those issues.
A partial closure

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