Income Tax Act 2007 section 698A

No-counteraction notices

Section 698A deals with the conclusion of HMRC enquiries into transactions in securities, requiring HMRC to issue either a counteraction notice or a no-counteraction notice, and giving taxpayers the right to apply to a tribunal to compel HMRC to conclude such enquiries within a specified period.

• Where HMRC concludes that no counteraction is needed following an enquiry, the officer must issue a "no-counteraction notice" explaining why no action is required.
• Taxpayers can apply to the tribunal to direct HMRC to issue either a counteraction notice or a no-counteraction notice within a set timeframe.
• The tribunal must grant the taxpayer's application unless HMRC can show reasonable grounds for not being able to issue either notice within the specified period.
• Any application to the tribunal is subject to the procedural rules in Part 5 of the Taxes Management Act 1970.