Taxation (International and Other Provisions) Act 2010 section 47

Completion of enquiry

Section 47 sets out how HMRC formally completes an enquiry into an interest restriction return, what the closure notice must contain, and the additional information required where the officer concludes the return was filed for the wrong period, group, or membership.

• An enquiry is completed when HMRC issues a closure notice informing the reporting company that the enquiry is finished and stating the officer's conclusions; the notice takes effect immediately on issue.
• If HMRC concludes the return should have covered one or more different periods of account, the closure notice must specify those periods, including the start and end dates of each.
• If HMRC concludes the return should have been filed in relation to a different worldwide group or groups, or a different group membership, the closure notice must identify each relevant period of account and provide sufficient details to identify the correct group(s) and their UK group company members.
• References to UK group companies for these purposes exclude any companies that were dormant throughout the period of account in question.

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