EM5620 - Commissioners: Application for a Closure Notice
TMA70/S28A(4)
TMA70/S28B(4)
TMA70/SCH1A/PARA 7(5)
FA98/SCH18/PARA 33
Detailed guidance on these applications can be found at
EM1975+.
This application will be heard and determined as if it was an
appeal. Both the taxpayer and the Revenue have the right to appeal
to the Courts if they are dissatisfied with the
Commissioners’ decision as being wrong in law.
Onus on Revenue
The Commissioners must give a direction unless they are
satisfied that you have reasonable grounds for not issuing a
closure notice and, where they do give a direction, they will
always give a time limit within which the notice must be issued.
This puts the onus on you to show why you should be allowed to
continue with your enquiries. You will need to be able to give the
Commissioners your reasons for continuing with an enquiry in all
cases, even where the case has been selected on a wholly random
basis as well as in cases which have been selected as a result of a
risk analysis.
The taxpayer’s right to seek a direction for a closure
notice does not affect your unconditional right to enquire into any
return. You should be prepared to emphasise this to the
Commissioners and to explain that you do not need to be
dissatisfied with a return before you can enquire into it.
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