EM2169 | Working the enquiry: partial closure notices: consequential claims

If we make assessments or amendments to recover a loss of tax, the legislation generally allows a taxpayer to make a claim for a relief or allowance for that same year, outside of the normal assessing time limits, see CH51300. We call these claims ‘consequential claims’.

Where a consequential claim is made following the issue of a partial closure notice (PCN), the claim should be actioned in the normal way. For Income Tax and Capital Gains Tax, see SACM9005+. For Corporation Tax, see CTM90645+ and EM3906.

Consequential claims are limited to the amount of additional tax due in the PCN.