There have been some interesting exchanges on LinkedIn about the length of time that HMRC has taken to close some enquiries in particular the fact that although there is a time limit governing the opening of enquiries there is no time limit for closing them. I was certainly aware in my days in practice of enquiries that had been going on for years with very little or nothing happening. Indeed I am pretty sure that in some cases some enquiries had entirely disappeared from HMRC’s radar and would never be concluded unless the taxpayer took action by seeking a closure notice.
When self assessment was introduced it was assumed that taxpayers making an application to close an enquiry would be commonplace. I understand that HMRC set up teams to deal with closure notice applications only to disband them when very few applications were made. Many taxpayers...
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