.png)
.png)
Strategic weaponry
Key points
- The Epaminondas Embiricos case clarifies of the scope of the partial closure notice regime.
- A partial closure notice allows other aspects of the enquiry to continue.
- By applying to the First-tier Tribunal a taxpayer can compel HMRC to issue a closure notice.
- HMRC must issue a notice unless there are reasonable grounds for not doing so.
- Has the department been provided with enough information to come to an informed judgment?
- HMRC’s arguments that it could not issue a notice relating to the taxpayer’s domicile status without information on foreign income and gains were clearly rejected.
- The precise extent of the regime remains to be seen.
As readers will be aware HMRC enquiries are frequently long-running particularly when they concern a taxpayer’s domicile status. The recent decision of the First-tier Tribunal in Epaminondas Embiricos (TC7083) is welcome news in this area. In particular it provides helpful clarification of the scope of the recently...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
