ETASSUM56120 | Enterprise Management Incentive (EMI): Option notifications: Completion of enquiry – Application for closure notice

Paragraph 48, Schedule 5 of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA)

The employer or the individual (in the case of an enquiry into the working time commitment) 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 the specified period.