Finance (No. 2) Act 2023

20 (1) This paragraph applies if a return is amended at a time when an enquiry is in progress into the return.

(2) The amendment does not restrict the scope of the enquiry but may be taken into account (together with any matters arising) in the enquiry (whether or not the amendment takes effect under sub-paragraph (4)).

(3) Sub-paragraph (4) applies where the amendment is made otherwise than under paragraph 19.

(4) So far as the amendment affects the amount stated in the return as the amount of tax payable, the amendment does not take effect, in relation to any matter to which it relates or which is affected by it, while the enquiry is in progress, except to the extent that—

(a) a partial closure notice has been given in relation to a matter to which the amendment relates or which is affected by it, and

(b) the notice states that the amendment is to take effect.

(5) The final closure notice—

(a) must state whether and to what extent an amendment whose effect is deferred under sub-paragraph (4) is to take effect;

(b) may state that an amendment made under paragraph 19, and whose effect is not terminated or amended by a partial closure notice, is to cease to have effect or is to be amended as specified in the notice.