What happens when HMRC reviews a closure notice and asks for more time?

Introduction

Readers often search for this issue when HMRC has already issued a closure notice, but an HMRC review officer then contacts the taxpayer or their adviser about extending the review deadline. The practical concern is usually simple: does the review continue automatically, can HMRC ask for more time, and what should the taxpayer do next?

This article explains the position in general terms using an anonymised scenario based on correspondence between an HMRC review officer and a taxpayer’s adviser.

The Question

A taxpayer received a closure notice, and HMRC later contacted the taxpayer’s adviser to discuss extending the deadline for the ongoing review. The immediate issue was not the technical tax merits, but the review process itself: how an HMRC review works, whether the time limit can be extended, and what practical steps should be taken when HMRC asks for more time.

Nick’s Explanation

Nick’s explanation, in substance, was procedural rather than controversial. The correspondence showed that HMRC’s review officer was trying to speak to the adviser about an extension to the current review deadline, and the adviser confirmed availability for a later call.

In anonymised form, the key point from Nick’s side was effectively: the call had not connected properly, but the adviser was willing to discuss the matter and speak with HMRC the following day.

That kind of exchange usually means the review is live, HMRC is aware of the statutory timetable, and the officer wants agreement if more time is needed to complete the review properly.

The Law

Where HMRC issues an appealable decision, the taxpayer may in many cases ask HMRC for a statutory review instead of going straight to the tribunal. The review regime is governed by the Taxes Management Act 1970 and related appeal provisions, depending on the tax involved. In a review, a different HMRC officer considers whether the original decision should be upheld, varied or cancelled.

In broad terms:

• HMRC must complete the review within the statutory review period.
• That period can usually be extended by agreement between HMRC and the taxpayer.
• If the review is concluded, HMRC should notify the taxpayer of the conclusions.
• If the taxpayer remains dissatisfied, the usual next step is an appeal to the First-tier Tribunal within the applicable time limit.

The exact statutory route depends on the underlying tax and decision type, but the procedural structure is well established: review first if requested or offered, then tribunal if the dispute remains unresolved.

Analysis

Step by step, the position is usually as follows.

First, HMRC has already issued a closure notice or other appealable decision. That means there is an identified decision which the taxpayer can challenge.

Second, a review is underway. The fact that an HMRC review officer refers to “the current review deadline” indicates that the matter is already within the statutory review framework.

Third, HMRC may decide that it cannot fairly complete the review within the original period. That can happen for many reasons, including the need to consider further documents, legal submissions or internal technical advice.

Fourth, HMRC cannot simply assume extra time where the legislation requires agreement. If an extension is needed, the officer will normally contact the taxpayer or the taxpayer’s adviser to seek consent.

Fifth, the taxpayer should not treat a request for more time as a mere administrative detail. Agreeing an extension may be sensible if it increases the chance of a proper reconsideration by HMRC, but the taxpayer should also consider whether delay is in their interests. In some cases, a taxpayer may prefer the review to end so the matter can move to tribunal.

Sixth, if the extension is agreed, it is best to confirm it clearly in writing, including the new deadline. If it is not agreed, the statutory consequences will depend on the relevant review provisions and timing, but the taxpayer should be ready to protect their tribunal appeal position.

Seventh, the underlying merits of the tax dispute remain separate from the procedural issue. A review extension does not itself decide whether HMRC’s substantive tax position is right or wrong.

Outcome

The practical takeaway is that an HMRC review officer can ask for more time to complete a review, but the taxpayer should check whether the extension requires agreement and should record any agreement clearly. The request does not itself determine the tax dispute. It is a procedural step in the review process.

Practical Steps

• Check what decision is under review and the date of the original closure notice or other appealable decision.
• Identify the statutory review deadline and whether HMRC is asking to extend it by agreement.
• Ask HMRC to confirm in writing why more time is needed and what new deadline is proposed.
• Consider whether an extension helps or harms your position. Sometimes a fuller HMRC review is useful; sometimes a prompt tribunal appeal is preferable.
• Keep a written record of all calls, emails and agreed deadlines.
• Make sure any tribunal appeal time limit is diarised and protected.
• If the dispute concerns SDLT or another technical tax issue, separate the procedural review point from the substantive legal argument.

Conclusion

If HMRC contacts you about extending a review deadline, that usually means the review is still ongoing and HMRC wants more time to complete it. The key is to understand the statutory timetable, decide whether agreeing extra time is in your interests, and keep the appeal position protected.

Legal References Used

• Taxes Management Act 1970
• Applicable statutory review and appeal provisions for the relevant tax in dispute
• First-tier Tribunal appeal procedure in tax cases

This page was last updated on 22 March 2026.

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