EM2162 | Working the enquiry: partial closure notices: appeals - taxpayer’s right to apply to the tribunal for a partial closure notice

At any time during the course of an enquiry, the taxpayer may apply to the tribunal for a direction that HMRC should issue either a partial closure notice (PCN) or a final closure notice (FCN).

Unless the tribunal is satisfied that HMRC has reasonable grounds for not giving a PCN they must give a direction in favour of the taxpayer. This puts the onus on HMRC officers to show why the enquiries should be allowed to continue. Any direction will specify when the PCN has to be issued by.

For more information on closure applications, see EM1975.

Where the tribunal gives a direction HMRC Officers should follow the guidance at EM1990.