It is possible that the decision of Henderson J in Tower MCashback will be reinstated — ie that a closure notice must contain all grounds on which HMRC may rely during an appeal — as the decision of the Court of Appeal — that HMRC are allowed to admit new grounds of challenge during the course of an appeal is itself being appealed. The Parties have sought leave to appeal to the Supreme Court. Leave may well be granted given the policy implications...
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It is possible that the decision of Henderson J in Tower MCashback will be reinstated — ie that a closure notice must contain all grounds on which HMRC may rely during an appeal — as the decision of the Court of Appeal — that HMRC are allowed to admit new grounds of challenge during the course of an appeal is itself being appealed. The Parties have sought leave to appeal to the Supreme Court. Leave may well be granted given the policy implications...
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