Taxes Management Act 1970 section 28A

Completion of enquiry into personal or trustee return

Section 28A sets out the rules for how HMRC formally completes an enquiry into a personal or trustee tax return, including the use of partial and final closure notices.

• HMRC may issue a "partial closure notice" to conclude specific matters within an enquiry, and a "final closure notice" to bring the entire enquiry to an end.
• Every closure notice — whether partial or final — must state HMRC's conclusions and either confirm that no amendment to the return is needed or make the necessary amendments.
• A closure notice takes effect as soon as it is issued.
• The taxpayer may apply to the tribunal for a direction requiring HMRC to issue a closure notice within a specified period, and the tribunal must grant this unless HMRC can show reasonable grounds for delay.