EM3801 - Concluding the Enquiry: Introduction

In many cases you will be able to agree with the taxpayer the additional amounts assessable. You may require from them

• a statement of assets and liabilities EM3805
• a certificate of disclosure EM3810

before moving towards settlement either by way of a contract offer or formally.

For years where you have an open SA enquiry your enquiry may be concluded using the statutory provisions EM3830+ if

1. you are not seeking penalties
2. you are unable to negotiate a contract offer with the taxpayer and you have to follow the formal route to conclude your enquiries EM3900+
3. the taxpayer’s application for a closure notice has resulted in an Appeal Commissioners direction EM1975+

For other years where there are open appeals against discovery assessments the statutory alternatives are

4. agreement under S54 or
5. determination or confirmation by the Appeal Commissioners

At any stage until penalties become final by formal action you will still be able to negotiate a contract settlement.

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