EM2165 | Working the enquiry: partial closure notices: completing issues where there are no tax consequences

Where you have concluded that one or more matters require amending in a return, but there are no tax consequences from the amendment, you should still follow the operational guidance at CH279600 before issuing a partial closure notice (PCN).

If the approving officer agrees that a PCN can be issued, the notice should reflect your conclusion. Where you are not making an amendment, you do not need to provide reasons for that conclusion.

The taxpayer can appeal against your conclusion or amendment in an ITSA case or amendment in a CTSA case, even though there are no tax consequences arising as a result of the amendment.