HMRC issuing closure notices without having opened an enquiry
Our pick of this week's cases
In Credit Suisse Securities (Europe) Ltd and others v HMRC [2020] UKFTT 86 (TC) (11 February) the First-tier Tribunal upheld a company’s appeal against a closure notice on the grounds that HMRC had not given a valid notice of enquiry.
The substantive issue was whether a deferred variable award scheme for employees (the ‘APPA’) operated by the company was subject to bank payroll tax (BPT) a temporary tax chargeable on certain remuneration awarded to employees of banks between December 2009 and April 2010. In accordance with HMRC’s usual practice for large businesses there were discussions about the APPA between the company and HMRC before its BPT return was filed on 31 August 2010 and those discussions continued after that date. During the course of the discussions the HMRC customer relationship manager became...
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HMRC issuing closure notices without having opened an enquiry
Our pick of this week's cases
In Credit Suisse Securities (Europe) Ltd and others v HMRC [2020] UKFTT 86 (TC) (11 February) the First-tier Tribunal upheld a company’s appeal against a closure notice on the grounds that HMRC had not given a valid notice of enquiry.
The substantive issue was whether a deferred variable award scheme for employees (the ‘APPA’) operated by the company was subject to bank payroll tax (BPT) a temporary tax chargeable on certain remuneration awarded to employees of banks between December 2009 and April 2010. In accordance with HMRC’s usual practice for large businesses there were discussions about the APPA between the company and HMRC before its BPT return was filed on 31 August 2010 and those discussions continued after that date. During the course of the discussions the HMRC customer relationship manager became...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
