Our pick of interesting case decisions handed down to date this year.
1. Embiricos: partial closure notices must state tax due
In Embiricos v HMRC [2022] EWCA Civ 3 (reported in Tax Journal 21 January 2022) the Court of Appeal upheld the Upper Tribunal’s decision that HMRC had no power to issue a partial closure notice in respect of the taxpayer’s domicile and remittance basis claim without specifying the increased tax due as a result.
At first sight the issue in this case is narrow albeit important for individuals embroiled in long-running domicile investigations: HMRC has no power to issue a partial closure notice in respect of the taxpayer’s domicile and remittance basis claim without specifying the increased tax due as a result (which would necessarily require HMRC having information regarding the individual’s unremitted foreign income...
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Our pick of interesting case decisions handed down to date this year.
1. Embiricos: partial closure notices must state tax due
In Embiricos v HMRC [2022] EWCA Civ 3 (reported in Tax Journal 21 January 2022) the Court of Appeal upheld the Upper Tribunal’s decision that HMRC had no power to issue a partial closure notice in respect of the taxpayer’s domicile and remittance basis claim without specifying the increased tax due as a result.
At first sight the issue in this case is narrow albeit important for individuals embroiled in long-running domicile investigations: HMRC has no power to issue a partial closure notice in respect of the taxpayer’s domicile and remittance basis claim without specifying the increased tax due as a result (which would necessarily require HMRC having information regarding the individual’s unremitted foreign income...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
