Taxes Management Act 1970 section 28B

Completion of enquiry into partnership return

Section 28B sets out how HMRC completes an enquiry into a partnership return, including the use of partial and final closure notices and the consequential amendments to individual partners' returns.

• HMRC may issue a partial closure notice to conclude specific matters within an enquiry, or a final closure notice to bring the entire enquiry to an end
• Every closure notice must state HMRC's conclusions and either confirm no amendment is needed or make the necessary amendments to the partnership return
• Where the partnership return is amended, HMRC must also amend each partner's individual or company tax return to reflect the changes
• The taxpayer may apply to the tribunal for a direction requiring HMRC to issue a closure notice within a specified period, and the tribunal must grant this unless there are reasonable grounds not to