Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal will exercise its power to direct HMRC to issue a closure notice in light of the recent case of Hitchins.
Where a tax return addresses complex issues and facts a lengthy enquiry may be inevitable. Frequently however enquiries can seem never-ending. Where discussions between the taxpayer and HMRC cannot progress matters there are limited options open to the taxpayer but the taxpayer can apply to the First-tier Tribunal (FTT) to direct HMRC to close their enquiries. Taxpayers are often reluctant to take this step but the recent case of Hitchins v HMRC [2023] UKFTT 127 (TC) illustrates how the FTT will approach matters and demonstrates the value of being more assertive in managing HMRC enquiries in the right circumstances.
Applying for a closure notice
HMRC has one year from when a tax return...
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Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal will exercise its power to direct HMRC to issue a closure notice in light of the recent case of Hitchins.
Where a tax return addresses complex issues and facts a lengthy enquiry may be inevitable. Frequently however enquiries can seem never-ending. Where discussions between the taxpayer and HMRC cannot progress matters there are limited options open to the taxpayer but the taxpayer can apply to the First-tier Tribunal (FTT) to direct HMRC to close their enquiries. Taxpayers are often reluctant to take this step but the recent case of Hitchins v HMRC [2023] UKFTT 127 (TC) illustrates how the FTT will approach matters and demonstrates the value of being more assertive in managing HMRC enquiries in the right circumstances.
Applying for a closure notice
HMRC has one year from when a tax return...
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:
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