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Back to basics: HMRC enquiries and obtaining closure

Adam Craggs and Jonathan Levy on ability to apply for a direction that the tax department issues a closure notice

One of the keenest areas of contention between HMRC and taxpayers is the length of time that enquiries often take before they are concluded. The legislation does not provide a time limit by which HMRC is required to conclude an enquiry and it is not uncommon for enquiries to become protracted and resource intensive. There will be occasions when a taxpayer decides that an enquiry has gone on for long enough and wishes to bring it to an end.

In this article we will consider the enquiry process the procedure by which a taxpayer may obtain a...

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