SDLTM82580 - Compliance: Concluding an enquiry

Closure notices: Closure applications by the purchaser: Repeated applications

There is no restriction on the number of closure applications that can be made during the course of an enquiry. FA03/SCH10/PARA21 states however that no such closure application may be made while proceedings on a referral are in progress in relation to an enquiry. FA03/SCH10/PARA19 covers referrals.

Some purchasers may make several closure applications during the course of an enquiry. How each application is dealt with depends on the stage of the enquiry at which it is made.

A closure application should also not be processed as normal when the application is made immediately after a Tax Tribunal has rejected an earlier one (in effect a protest against the direction). In these circumstances the purchaser should be advised that they have no grounds for making the further application. If the purchaser persists Head Office should be contacted immediately.

If the rejection of a closure application is followed by delay on the Stamp Office's part, then any subsequent application should be processed normally, even if the circumstances have not altered since the earlier application was rejected.