JHA | The draft Finance Bill (No.2) - Partial Closure Notices

The draft Finance Bill (No.2) – Partial Closure Notices

September 28, 2017


The draft Finance Bill (No.2) contains provisions to allow HMRC to issue “Partial Closure Notices”. Partial Closure Notices will operate substantially the same way for individuals and trusts, partnerships and companies. HMRC will be able to issue closure notices for individual aspects (“matters” as they are referred to in legislation) of an enquiry before they have to close the entire enquiry. The effect on the individual matter closed will be the same as if a closure notice had been issued under the current system, including all the usual knock-on effects of time limits for amendments, appeals etc. relating to that individual matter. This power will supposedly allow HMRC to resolve simpler issues quickly without them dragging along behind more complicated and long-running arguments.

Taxpayers remain able to apply to the tribunal for a full closure notice, but will also be able to apply for a partial closure notice.


This article appears in the JHA September 2017 Tax Newsletter, which also features:

  1. First ever GAAR Advisory Panel Opinion
  2. Beneficial Ownership Limitations must target only artificial arrangements
  3. The Trustees of the BT Pension Scheme C-628/15: Tax Credits for Exempt Taxpayers
  4. Trustees of the P Panayi Accumulation & Maintenance Settlements: Exit Charge on Trust Migration
  5. Cussens & Others C-251/16: Abuse of Rights

You can download the whole newsletter as a PDF: September 2017 – Newsletter