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Taking the position of a partner who disagrees with the outcome of an enquiry into a partnership return
KEY POINTS
- Figures in a partnership return do not bind the individual partners
- Partnership enquiries are carried out between HMRC and the representative partner
- Right of appeal against a partnership closure notice
- Impact on the settlement opportunity for taxpayers in partnership avoidance schemes
It is well known that a number of the avoidance schemes currently under HMRC enquiry relate to partnerships. Indeed their perceived abuse for tax avoidance purposes led to the Budget day announcement of a consultation document on certain aspects of partnership taxation.
This article however concerns some more fundamental procedural aspects of partnership enquiries and in particular the position of a partner who disagrees with the conclusions reached on an enquiry into the partnership’s return.
Partnerships are required to file tax returns under TMA 1970 s 12AA. It...
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