An HMRC enquiry into a tax return ends with a closure notice. It states HMRC’s conclusions and makes any changes to the return. If you disagree, you have 30 days from the date of the notice to appeal in writing. If HMRC is taking too long, you can apply to the tax tribunal for a direction that HMRC close the enquiry, and the tribunal must give it unless HMRC shows reasonable grounds for keeping it open.

What is a closure notice?

Section 28A of the Taxes Management Act 1970 provides for two kinds of notice for Self Assessment returns:

  • a partial closure notice, which completes the enquiry into one particular matter;
  • a final closure notice, which completes the whole enquiry, or whatever remains open if partial notices have already been given.

Each notice states HMRC’s conclusions and makes any amendments needed to the return. Company Tax Returns have equivalent rules in Schedule 18 to the Finance Act 1998.

What happens if the closure notice changes my return?

The extra tax becomes payable, normally with late payment interest, and HMRC may issue a separate penalty decision. See HMRC penalties for tax return errors.

How do I appeal a closure notice?

Section 31A of the Act says an appeal must be made in writing, within 30 days after the date the closure notice was issued, to the officer who gave it, and must state the grounds. Once you appeal, HMRC will usually offer a statutory review, or you can take the appeal to the First tier Tribunal. Our guide to statutory review and the tax tribunal explains what happens next, and alternative dispute resolution is another option.

Can I make HMRC close an enquiry?

Yes. Under section 28A(4) you can apply to the tribunal for a direction requiring HMRC to issue a partial or final closure notice within a specified period. Under section 28A(6) the tribunal must give the direction unless it is satisfied that HMRC has reasonable grounds for not issuing the notice. Companies have the same right under paragraph 33 of Schedule 18. Applications are usually worth considering when HMRC has the information it needs but has gone quiet.

Can HMRC reopen a return after a closure notice?

An enquiry cannot be reopened once closed. HMRC can still raise a discovery assessment in limited circumstances, for example if it later finds something it could not reasonably have known about from the information it had. Our guide to how far back HMRC can go sets out the time limits.

Who pays for the work up to closure?

HMRC does not pay your accountant’s fees, whatever the outcome. Tax investigation insurance does, for enquiries opened after your cover starts, and Solar Protect cover pays up to £100,000 with no excess. Read how our cover works or get a quote today.

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 7 October 2026. Sources: Taxes Management Act 1970 sections 28A and 31A; Finance Act 1998 Schedule 18. This guide is general information, not personalised tax advice.