SDLTM82520 - Compliance: Concluding an enquiry

Closure notices: Closure applications by the purchaser: General information

At any time during the course of an enquiry, the purchaser may apply to a Tax Tribunal for a direction that HM Revenue & Customs should issue a closure notice within a period specified by the Tribunal.

The Tax Tribunal must give a direction unless they are satisfied that HM Revenue & Customs have reasonable grounds for not giving a closure notice within a specified period.

The application is to be heard and determined in the same way as an appeal under FA03/SCH10/PARA24.

By statute the application is direct to the Tribunal Service.

It is unlikely initially that any action will be taken which will result in application to a Tax Tribunal. If however this does occur immediate reference must be made to Head Office, by telephone in the first instance.