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DAVID SEARLE and MIKE DOWN are happy to share their favourable first impressions of HMRC’s new independent review process
KEY POINTS
- Enquiry into non-domiciled UK resident.
- Was a request for offshore bank statements reasonable?
- Could a properly instructed tribunal have reached the same conclusion?
- The closure notice and the unexpectedly increased liability.
- A request for an independent review.
- Cause for optimism about the review process.
Readers of this magazine may recall Mike Truman’s article House of cards in which he reported on the decision of the General Commissioners in the case of Mrs A.
The case generated much interest within the tax profession because it highlighted HMRC’s attitude towards seeking information from resident but non-domiciled individuals.
To recap Mrs A’s 2006/07 tax return showed no foreign remittances taxable in the UK. HMRC launched an enquiry and sought copy statements for all bank accounts including those...
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