SDLTM82540 - Compliance: Concluding an enquiry

Closure notices: Closure applications by the purchaser: Following a request for information

Although the purchaser has no right of appeal against an FA03/SCH10/PARA12 notice of enquiry they are entitled under FA03/SCH10/PARA24 to ask A Tax Tribunal to direct that the enquiry be completed at any time after the issue of the notice.

Some purchasers or their agents may want to apply for a closure notice immediately on receipt of the opening letter. In effect, any such application will amount to a challenge to the Stamp Office’s right to enquire into the land transaction return.

If a compliance caseworker meets this situation in practice they should not normally have any difficulty in showing that a direction is not appropriate. At this early stage of the enquiry it is unlikely that the purchaser will have any real grounds for seeking a Tax Tribunal direction.

If the purchaser or agent makes an application, it should be explained to them why the application is not appropriate at this point and they should be asked to withdraw it. But if the application is pursued Head Office should be contacted immediately.