Adam Craggs (RPC) reviews the decision in Mabbutt, which serves as an important reminder of the essential elements of a valid notice of enquiry into an individual’s specific tax return.
As readers will be aware TMA 1970 s 114 permits HMRC and taxpayers to rely on assessments determinations and other proceedings containing errors provided the documents concerned are in substance and effect in conformity with the intent and meaning of the Taxes Acts. Documents will not conform with the substance and effect of legislation if the error is fundamental.
In the recent case of Mabbutt v HMRC [2016] UKFTT 0306 the taxpayer appealed to the First-tier Tribunal (FTT) against a closure notice dated 1 July 2014 relating to the 2008/09 tax year (the closure notice). The closure notice assessed additional tax of £653 000 in...
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Adam Craggs (RPC) reviews the decision in Mabbutt, which serves as an important reminder of the essential elements of a valid notice of enquiry into an individual’s specific tax return.
As readers will be aware TMA 1970 s 114 permits HMRC and taxpayers to rely on assessments determinations and other proceedings containing errors provided the documents concerned are in substance and effect in conformity with the intent and meaning of the Taxes Acts. Documents will not conform with the substance and effect of legislation if the error is fundamental.
In the recent case of Mabbutt v HMRC [2016] UKFTT 0306 the taxpayer appealed to the First-tier Tribunal (FTT) against a closure notice dated 1 July 2014 relating to the 2008/09 tax year (the closure notice). The closure notice assessed additional tax of £653 000 in...
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:
