Income Tax (Earnings and Pensions) Act 2003 Schedule 5 paragraph 48

Completion of enquiry: application for closure notice to be given

Schedule 5 paragraph 48 deals with the right to apply to the tribunal to compel HMRC to conclude an enquiry by issuing a closure notice within a specified timeframe.

• An application can be made to the tribunal for a direction requiring HMRC to issue a closure notice within a specified period
• The application may be made by the employer company or, in certain cases, by the individual concerned
• The application process is governed by the relevant provisions of Part 5 of the Taxes Management Act 1970
• The tribunal must issue the direction unless satisfied that HMRC has reasonable grounds for not giving a closure notice within the specified period