Taxation (International and Other Provisions) Act 2010 section 48

Direction to complete enquiry

Section 48 allows the reporting company to apply to the tribunal for a direction requiring HMRC to complete its enquiry into an interest restriction return within a specified timeframe.

• The reporting company may apply to the tribunal at any time for a direction requiring HMRC to issue a closure notice within a specified period.
• Only the reporting company that submitted the interest restriction return for the relevant period of account may make the application.
• The application is subject to the procedural rules in Part 5 of the Taxes Management Act 1970, including section 48(2)(b) of that Act.
• The tribunal must issue the direction unless HMRC can demonstrate reasonable grounds for needing more time before closing the enquiry.