{
  "url": "https://openlegislation.uk/taxes-management-act-1970/section-28A",
  "json_url": "https://openlegislation.uk/taxes-management-act-1970/section-28A.json",
  "legislation": "ukpga/1970/9",
  "legislation_title": "Taxes Management Act 1970",
  "legislation_url": "https://openlegislation.uk/taxes-management-act-1970",
  "path": "section/28A",
  "kind": "section",
  "number": "28A",
  "heading": "Completion of enquiry into personal or trustee return ...",
  "text": "(1) This section applies in relation to an enquiry under section 9A(1) ... of this Act.\n(1A) Any matter to which the enquiry relates is completed when an officer of Revenue and Customs informs the taxpayer by notice (a “partial closure notice”) that the officer has completed his enquiries into that matter.\n(1B) The enquiry is completed when an officer of Revenue and Customs informs the taxpayer by notice (a “final closure notice”) —\n(a) in a case where no partial closure notice has been given, that the officer has completed his enquiries, or\n(b) in a case where one or more partial closure notices have been given, that the officer has completed his remaining enquiries.\n(2) A partial or final closure notice must state the officer's conclusions and—\n(a) state that in the officer’s opinion no amendment of the return is required, or\n(b) make the amendments of the return required to give effect to his conclusions.\n(3) A partial or final closure notice takes effect when it is issued.\n(4) The taxpayer may apply to the tribunal for a direction requiring an officer of the Board to issue a partial or final closure notice within a specified period.\n(5) Any such application is to be subject to the relevant provisions of Part 5 of this Act (see, in particular, section 48(2)(b)).\n(6) The tribunal shall give the direction applied for unless ... satisfied that there are reasonable grounds for not issuing the partial or final closure notice within a specified period.\n(7) In this section “the taxpayer” means the person to whom notice of enquiry was given.\n(8) In the Taxes Acts, references to a closure notice under this section are to a partial or final closure notice under this section.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "S. 28A substituted (with effect and application in accordance with s. 88(3), Sch. 29 para. 8(2) of the amending Act) by Finance Act 2001 (c. 9), Sch. 29 para. 8(1)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "S. 28A(1)-(1B) substituted for s. 28A(1) (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(2)"
    },
    {
      "type": "F",
      "label": "F3",
      "text": "Words in s. 28A(1) omitted (with effect in accordance with Sch. 2 para. 32(1) of the amending Act) by virtue of Finance Act 2019 (c. 1), Sch. 2 para. 25(4)(a)"
    },
    {
      "type": "F",
      "label": "F4",
      "text": "Words in s. 28A(2) substituted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(3)(a)"
    },
    {
      "type": "F",
      "label": "F5",
      "text": "Words in s. 28A(2) substituted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(3)(b)"
    },
    {
      "type": "F",
      "label": "F6",
      "text": "Words in s. 28A(3) substituted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(4)"
    },
    {
      "type": "F",
      "label": "F7",
      "text": "Word in s. 28A(4) substituted (1.4.2009) by The Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009 (S.I. 2009/56), art. 1(2), Sch. 1 para. 17(2)"
    },
    {
      "type": "F",
      "label": "F8",
      "text": "Words in s. 28A(4) substituted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(4)"
    },
    {
      "type": "F",
      "label": "F9",
      "text": "S. 28A(5) substituted (1.4.2009) by The Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009 (S.I. 2009/56), art. 1(2), Sch. 1 para. 17(3)"
    },
    {
      "type": "F",
      "label": "F10",
      "text": "Word in s. 28A(6) substituted (1.4.2009) by The Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009 (S.I. 2009/56), art. 1(2), Sch. 1 para. 17(4)(a)"
    },
    {
      "type": "F",
      "label": "F11",
      "text": "Words in s. 28A(6) omitted (1.4.2009) by virtue of The Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009 (S.I. 2009/56), art. 1(2), Sch. 1 para. 17(4)(b)"
    },
    {
      "type": "F",
      "label": "F12",
      "text": "Words in s. 28A(6) substituted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(5)"
    },
    {
      "type": "F",
      "label": "F13",
      "text": "S. 28A(7)(8) inserted (with effect in accordance with Sch. 15 para. 44 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 15 para. 12(6)"
    },
    {
      "type": "F",
      "label": "F14",
      "text": "Words in s. 28A heading omitted (with effect in accordance with Sch. 2 para. 32(1) of the amending Act) by virtue of Finance Act 2019 (c. 1), Sch. 2 para. 25(4)(b)"
    },
    {
      "type": "C",
      "label": "C1",
      "text": "S. 28A applied (with modifications) (with effect in accordance with Sch. 2 para. 24(2) of the amending Act) by Finance Act 2019 (c. 1), Sch. 2 para. 20(7)"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "Pts. 4-6 applied (22.7.2020) by Finance Act 2020 (c. 14), Sch. 16 para. 9(3)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1970/9/section/28A",
    "retrieved_at": "2026-10-29T10:51:31.747484+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}