ETASSUM27130 - Schedule 2 share incentive plan (SIP): Notification & Enquiries: Application for closure notice
The company which established the plan may apply to the Tribunal to direct HMRC to issue a closure notice within a specified period. The Tribunal hearing the application, which must be heard and determined in the same way as an appeal, will give a direction, unless it is satisfied that there are reasonable grounds for not giving a closure notice within a specified period (paragraph 81G(2)).