Adam Craggs and Liam McKay (RPC) provide a refresher guide.
Historically taxpayers have not taken the initiative in bringing long-running enquiries to an end. However increasingly taxpayers are adopting a more proactive approach and are seeking an appropriate direction from the First-tier Tribunal (FTT) requiring HMRC to issue a closure notice within a specified period. An enquiry is completed when HMRC issue a closure notice informing the taxpayer that they have completed their enquiries and stating their conclusion. In this article we consider the process by which the FTT can compel HMRC to close their enquiry HMRC’s internal review procedure and prosecuting an appeal before the FTT with a focus on the provisions concerning enquiries and appeals in respect of income tax.
Closure notice applications
Where a taxpayer considers that HMRC have sufficient information and an enquiry has become protracted and HMRC are refusing...
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Adam Craggs and Liam McKay (RPC) provide a refresher guide.
Historically taxpayers have not taken the initiative in bringing long-running enquiries to an end. However increasingly taxpayers are adopting a more proactive approach and are seeking an appropriate direction from the First-tier Tribunal (FTT) requiring HMRC to issue a closure notice within a specified period. An enquiry is completed when HMRC issue a closure notice informing the taxpayer that they have completed their enquiries and stating their conclusion. In this article we consider the process by which the FTT can compel HMRC to close their enquiry HMRC’s internal review procedure and prosecuting an appeal before the FTT with a focus on the provisions concerning enquiries and appeals in respect of income tax.
Closure notice applications
Where a taxpayer considers that HMRC have sufficient information and an enquiry has become protracted and HMRC are refusing...
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:
