HMRC amendments to closure notices

[interestedparty]

Hi, my understanding was that as far as changes to closure notices are concerned, closure means closure and cannot be subsequently changed by HMRC. But I've now read that HMRC can, under discovery provisions, raise a further assessment if additional information came to light that was not made available during the inquiry. How do they determine what and wasn't made available to them during the inquiry - if I provided everything I was asked for whilst the inquiry was still open, and a closure notice issued, then can HMRC raise another assessment based on new information that was never requested during the inquiry? I'm struggling to understand what does, and what doesn't constitute additional information coming to light?

[DealorNoDeal]

I would have thought there would be a high bar for re-assessing a year that has been closed with a CN. Deliberate concealment/non-disclosure would probably be grounds. Apart from anything else, HMRC have got more than enough on their plate to go revisiting closed off years.

[TheDogsNads]

Hi, my understanding was that as far as changes to closure notices are concerned, closure means closure and cannot be subsequently changed by HMRC. But I've now read that HMRC can, under discovery provisions, raise a further assessment if additional information came to light that was not made available during the inquiry. How do they determine what and wasn't made available to them during the inquiry - if I provided everything I was asked for whilst the inquiry was still open, and a closure notice issued, then can HMRC raise another assessment based on new information that was never requested during the inquiry? I'm struggling to understand what does, and what doesn't constitute additional information coming to light?

It's because HMRC are a law unto themselves, they can pretty much do what they want. They know they can re open under discovery provisions under the flimsiest of excuses because if the recipient doesnt agree, they have to appeal to an FTT with all the time and effort that takes.

As for the following suggestion that HMRC 'have enough' on their plate, what betty swallocks! They have 'enough on their plate' because they're intent on chasing every tax payer for their pound of flesh.

[DealorNoDeal]

As for the following suggestion that HMRC 'have enough' on their plate, what betty swallocks! They have 'enough on their plate' because they're intent on chasing every tax payer for their pound of flesh.

I've never come across a single case of someone settling, after receiving Closure Notices, and HMRC re-opening them. Maybe you know different.

Anyway, I would put money on it that this is exceptionally rare.

[TheDogsNads]

I've never come across a single case of someone settling, after receiving Closure Notices, and HMRC re-opening them. Maybe you know different.

Anyway, I would put money on it that this is exceptionally rare.

Good for you. Maybe people should just follow your advice of 'contacting their MP'!

[DealorNoDeal]

Good for you. Maybe people should just follow your advice of 'contacting their MP'!

If HMRC re-open your settled Closure Notices, absolutely!

[Chevalier]

HMRC in my opinion have been quite poor at keeping a full cross referenced database of enquiries, and it seems they just keep lists of tax payers from different sources. It’s quite possible that you appear in their lists multiple times, which might explain why you have a discovery notice for something already settled.

[handyandy]

I don’t think the OP said he’d had a closed inquiry reopened after receiving a closure notice - just that he was worried he’d heard it could happen. I think to reassure him, whilst it is possible it is highly unlikely for them to do this and you should get on with your life in the expectation that this is now over. Obviously if you have deliberately misled them they may find out and come after you but in the likely event that you are like the vast majority of us you should start relaxing.

[DealorNoDeal]

I don’t think the OP said he’d had a closed inquiry reopened after receiving a closure notice - just that he was worried he’d heard it could happen. I think to reassure him, whilst it is possible it is highly unlikely for them to do this and you should get on with your life in the expectation that this is now over. Obviously if you have deliberately misled them they may find out and come after you but in the likely event that you are like the vast majority of us you should start relaxing.

^^This^^

[interestedparty]

^^This^^

Thanks for all of your advice and comments. Initially I was told that "further details were required from another HMRC department on some technical points" which led me to think that the closure notice would be amended. Now they saying that the closure notices did not consider transactions in my limited company bank account (which I closed many years ago, along with the limited company itself), and that the limited company is separate from my tax liability as an individual contractor. The limited company was only ever used in conjunction with my contractor status under the Procorre (and Glen May) schemes. They also want to investigate the corporate card that the promoter issued to contractors to reimburse what they termed 'expenses". I hope this clarifies things - apologies for not being clearer when I originally posted.