Article 124 - Completion of Enquiry

(1) An enquiry into a return filed under Article 109 is completed when the Tax Department by notice (a "closure notice") informs the QFC Entity whose return it is that they have completed their enquiry and state their conclusions. The notice takes effect when it is issued.
(2) A closure notice must either—
(a) state that in the opinion of the Tax Department no amendment of the return is required; or
(b) make the amendments to the return to give effect to the conclusions.
(3) A QFC Entity whose return is subject to an enquiry may apply, by way of an appeal, for a direction requiring the Tax Department to issue a closure notice within a specific period.
(4) Where an application under this Article is heard by The Regulatory Tribunal, that tribunal shall give the direction applied for under Article 124(3) unless they are satisfied the Tax Department has reasonable grounds for not giving a closure notice within a specified period.
(5) An amendment of a return under Article 124(2)(b) shall displace any amendment of a self-assessment made during the course of the enquiry under Article 123.
Amended (as from 18th June 2014)