The officer’s enquiry is ‘completed’ when he, by a ‘closure notice’, informs the taxpayer that he has completed his enquiries and states his conclusions (TMA 1970, s. 28A(1) as substituted by FA 2001, Sch. 29, para. 8(1), applying where the notice of enquiry is given after 11 May 2001 or was in progress immediately before that date; formerly TMA 1970, s. 28A(5)).

The closure notice must either:

(1)state that in the officer’s opinion no amendment of the return is required; or

(2)make the amendments of the return required to give effect to his conclusions (TMA 1970, s. 28A(2), substituted as above).

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