SALF406 - Enquiries into Tax Returns: Referrals to the Special Commissioners during an Enquiry
HMRC and the taxpayer can jointly refer an issue that is the subject of an open enquiry for determination by the Special Commissioners during the enquiry
Sections 28ZA to 28ZE
| 4.64 | In most cases a contentious issue that arises within an enquiry can be dealt with through the appeal procedures at the end of the enquiry. But where both HMRC and the taxpayer want a particular issue determined by the Special Commissioners before an enquiry is completed, they can refer the matter together to the Special Commissioners. The matter will be heard and determined by the Special Commissioners in the same way as an appeal and the determination is binding on the parties. It will be taken into account in the enquiry closure notice (see para 4.65). |
