Requesting closure of a compliance check

Produced by Tolley in association with

Owner-Managed Businesses

Guidance

At any time during the course of a compliance check, a taxpayer may apply to the Tribunal for a direction that HMRC should issue either a final or partial closure notice within a period specified by the Tribunal. See the Amendments to a return during a compliance check guidance note. See TMA 1970, ss 28A(4), 28B(5) for individuals and trustees, and for partnerships, respectively, and FA 1998, Sch 18, Part IV, para 33(1) for companies.

Note that this guidance note uses the term ‘compliance check’ in line with HMRC’s current terminology. However, the term ‘enquiry’ is still used in the referenced legislation.

Open compliance checks

An application for a partial or final closure notice will relate to formal compliance checks opened by HMRC under TMA 1970, s 9A (for individuals and trustees), TMA 1970, s 12AC (for partnerships) or FA 1998, Sch 18, Part IV, para 24 (for companies). Closure applications can only be made in relation to compliance checks opened using these formal powers.

An adviser should be mindful

Continue reading the full document

To gain access to additional expert tax guidance, workflow tools, and tax research, register for a free trial of Tolley+™

TAKE A FREE TRIAL NOW

Popular Articles

Corporation Tax

Foreign exchange issues

Foreign exchange issuesOverview of foreign exchange provisionsForeign exchange (FX) movements are generally taxed following the rules applicable to the underlying income, expenditure, asset or liability on which they arise, broadly as follows:Capital assetsOn a realisation basis (ie on disposal)

14 Jul 2020 11:44 | Produced by Tolley Read more

Owner-Managed Businesses

Repairs and renewals

Repairs and renewalsThe key consideration in determining whether expenditure on repairs and renewals is allowable as a deduction for tax purposes is whether it is capital or revenue in nature. In some cases, it can be relatively straightforward to identify revenue repairs. HMRC provides the

14 Jul 2020 13:23 | Produced by Tolley Read more

Corporation Tax

Computation of corporation tax

Computation of corporation taxCompanies pay corporation tax on the taxable total profits (TTP) generated in a chargeable accounting period (CAP).To ascertain whether the entity is within the charge to corporation tax, see the Charge to corporation tax guidance note.For more information on the type

14 Jul 2020 11:16 | Produced by Tolley Read more

��Ƶ