Taxation (International and Other Provisions) Act 2010 section 64

Notices following submitted interest restriction returns

Section 64 restricts HMRC's ability to issue certain notices once an interest restriction return has been submitted for a period of account.

• Once HMRC has received an interest restriction return for a period of account, it generally cannot issue a notice under paragraph 62 (requiring submission of a return) or paragraph 63 (appointing a reporting company) for that same period.
• This protection reflects the principle that, once a return has been properly submitted, HMRC should not need to compel actions that have already been taken.
• However, this protection does not apply if HMRC has opened an enquiry into the submitted return and that enquiry remains open.
• During an open enquiry, HMRC retains its full powers to issue notices under paragraphs 62 or 63 in relation to that period of account.