EM2165 - Working the enquiry: partial closure notices: completing issues where there are no tax consequences
Where you have concluded that one or more matters require amending in a return, but there are no tax consequences from the amendment, you should still follow the operational guidance at CH279600 before issuing a partial closure notice (PCN).
If the approving officer agrees that a PCN can be issued, the notice should reflect your conclusion. Where you are not making an amendment, you do not need to provide reasons for that conclusion.
»Ê¹ÚÌåÓýapp taxpayer can appeal against your conclusion or amendment in an ITSA case or amendment in a CTSA case, even though there are no tax consequences arising as a result of the amendment.