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Amrolia and the principle of finality

27 April 2021 / David Rangeley
Issue: 4789 / Categories: Comment & Analysis
It’s final – or is it?

Key points

  • HMRC’s mechanism for recovering over-repaid tax.
  • The De Silva judgment suggested an alternative method.
  • A deemed enquiry into a tax return now needs a TMA 1970 s 28A notice to close it.
  • The law on partnership enquiries needs to be clarified.

It surprises me that so little comment has appeared in these pages and indeed in other professional journals on the implications of the Court of Appeal judgment last year in R (on the application of Amrolia and Ranjit-Singh) v CRC [2020] STC 877. In this article I will illustrate how this decision not only offends the principle of finality which is supposed to underpin the self-assessment regime but also creates serious anomalies some working for and some against HMRC.

The genesis of the case goes back to 2014 when taxpayers who had entered film and other tax planning schemes claimed loss reliefs...

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