The new facility for partial closure notices

The Finance Bill 2017 will, among other things, introduce new legislation enabling HMRC to issue a partial closure notice at its own discretion, or with the agreement of the taxpayer, as well as enabling taxpayers to apply to the tribunal for a partial closure notice. The new rules will therefore provide a mechanism for HMRC and/or taxpayers to achieve closure in relation to specific discrete issues, while others remain under enquiry. Where HMRC issues a partial closure notice and amends a tax return, taxpayers will have the right to appeal the partial closure notice and ask for payment of the tax claimed to be postponed.