Mark McLaughlin looks at partial enquiry notices in the context of self-assessment tax return enquiries for individuals.
Tax return enquiries by HMRC can be long and intrusive. Taxpayers may sometimes feel aggrieved that an HMRC enquiry into their tax return has become unduly protracted. There is a facility for taxpayers to apply to the tribunal for a direction requiring HMRC to issue a final closure notice within a specified period (e.g. TMA 1970, s 28A for individuals). If the application is successful, the period specified by the tribunal for HMRC to close the enquiry can vary, generally from 30 days upwards (e.g. see Bloomfield v Revenue and Customs [2013] UKFTT 593 (TC)).
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