COM71092 - Enquiries: CTSA enquiries: closing an enquiry: non-contract settlement cases (Action Guide)

To close an enquiry in a non-contract settlement case, consider steps 1 - 10 below. The guide is presented as follows

Amendment anticipating conclusions in a Closure Notice Step 1
Enquiry does not result in an amendment to the return Step 2
Enquiry into return for the wrong period Step 3
Enquiry requiring change of return version Step 4
Issuing the Closure Notice with COTAX Steps 5 - 7
Appeals against Jeopardy Amendments Step 8
Amendment / claim received after HMRC enquiry concluded Step 9
Interaction with CQI or Caseflow Step 10

Amendment anticipating conclusions in a Closure Notice

1. If you receive a revised computation that fully and accurately anticipates your conclusions before you have stated them in a Closure Notice with Revenue Amendment
 
  • See the ‘Closing An Enquiry: Manual Closure Notices’ (COM71093) Action Guide

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Enquiry does not result in an amendment to the return

2. If the enquiry does not result in an amendment to the return
 
  • See the ‘Closing An Enquiry: Manual Closure Notices’ (COM71093) Action Guide

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Enquiry into return for the wrong period

3. If you conclude that a company tax return under enquiry is for the wrong period you will need to amend the company's AP record to show the correct period or periods before you issue the Closure Notice with Revenue Amendment
 
  • See subject ‘Enquiry Into Return For The Wrong Period’ (COM71060)

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Enquiry requiring change of return version

4. If a Version 1 CT600 return form is delivered and your Closure Notice with Revenue Amendment needs to include entries that are only available on a Version 2 CT600 form
 
  • See subject ‘Enquiry Requiring Change of Return Version’ (COM71070)

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Issuing the Closure Notice with COTAX

5. Use Function RAMA (Record / Amend Assessment), ‘Prepare a Closure Notice with Rev Amdt’ option, when you are ready to complete the enquiry, unless
 
  • You are settling the enquiry by contract settlement. (For information about contract settlements, see the Enquiry Manual at EM6000 onwards and subject ‘Closing An Enquiry: Contract Settlements’ (COM71120))
 
  • You need to issue a manual Closure Notice with Revenue Amendment. (See the ‘Closing An Enquiry: Manual Closure Notices’ (COM71093) Action Guide)
6. Function RAMA displays the details captured from the company’s return or as amended by later amendments
 

Note: Those details might include the figures from a Jeopardy Amendment (Word 29KB) made during the enquiry. See subjects ‘Making Jeopardy Amendments’ (COM71040) and ‘Appeals Against Jeopardy Amendments’ (COM71050)

 

They will not include the figures from a Taxpayer Amendment (Word 30KB) made during the enquiry, as it does not take effect until after the enquiry is completed. (Para 31(3) FA 1998) See subject ‘Taxpayer Amendments’ (COM71020)

 
  • Adjust the figures, in RAMA screen COT121N, to reflect the outcome of the enquiry
 
  • Include the effect of any Taxpayer Amendment deferred under Para 31(3)
 

Note: If a Taxpayer Amendment was made during the enquiry and, exceptionally, you have not considered the amendment during your enquiry, you should state this in the Closure Notice (Word 28KB) 

 
    • Use the free format message field in Function RAMA to enter an appropriate message
7. COTAX
 
  • Displays, where appropriate, a penalty action dialog box at the end of Function RAMA which allows you to make, amend or inhibit any tax-related (Word 30KB) penalty determination based on the amended assessment
 
  • Issues a Closure Notice showing your conclusions and incorporating your Revenue Amendment of the return
 
  • Creates the relevant postings in Function VPPD (View Payments and Postings)
 
  • Inhibits automatic repayments and reallocations for 14 days
 

The 14 day period gives you the time to deal with the consequences of your enquiry, for example, where you are amending more than one return at the same time

 
  • Enters the Enquiry End Date equal to the date of issue of the Closure Notice
 
 

You can see the status of those signals in Function DAPD (Display AP Details)

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Appeals against Jeopardy Amendments

8. If there is an open appeal against a Jeopardy Amendment you will need to dispose of it
 
  • See subject ‘Appeals Against Jeopardy Amendments’ (COM71050), which tells you how to dispose of appeals against Jeopardy Amendments

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Amendment / claim received after HMRC enquiry concluded

9. If the company claims to make or withdraw group relief and capital allowances after you have concluded your enquiry
 
  • See subject ‘Amendment / claim received after HMRC enquiry concluded’ in ‘Taxpayer Amendments’ (COM71020)

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Interaction with CQI or Caseflow

10. If your office uses CQI or Caseflow
 
  • Update it with the settlement details once the enquiry is settled in COTAX