DST61700 - Closing a Compliance Check via Closure Notices

HMRC must issue a closure notice to the Responsible Member at the end of every compliance check for each accounting period.

A compliance check is only finished when HMRC has given written notice to the Responsible Member of a group stated the conclusions of the check.

When it is issued, the closure notice takes effect and amends the return giving effect to the conclusions stated in the notice.

If there is a jeopardy amendment

See DST61500 for guidance on how closing a compliance check is affected by the existence of a jeopardy amendment.

Amendment anticipating conclusions in a closure notice

See DST61400 for guidance on dealing with an amendment that anticipates the conclusions in a closure notice.

Right of appeal

The group, through its Responsible Member, can appeal against a revenue amendment and the normal rules for appeals and postponement applications apply. It can then negotiate further, settle under Para 44 Sch 8 Finance Act 2020, ask for a review, or notify the appeal to the Tribunal.

Reissuing a closure notice

Reissuing a closure notice is not a routine procedure. HMRC will not do so unless there is a good reason to believe or accept that the original closure notice has not been received by the Responsible Member of a group.

If Royal Mail return the closure notice undelivered, HMRC cannot reissue it until a new address is entered on the group’s record.