HMRC opened an enquiry into my client’s 2022-23 capital gains tax in June last year. It wanted more information about three transactions which were a little complex so the request was not unreasonable. We provided detailed explanations and further evidence.
Over the ensuing months with more questions and more evidence the department accepted that two of the transactions were fine. It is still pursuing the third even though in my and my client’s view we have given enough information to demonstrate beyond reasonable doubt that this was a transaction at arm’s length and at market value.
My question is do readers have any experience of applying for a closure notice? We cannot appeal because HMRC has not made a decision – it has not even said what the ‘correct’ answer should be. It just keeps asking questions. I would like to make HMRC to...
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