In Refinitiv Ltd and others v HMRC [2025] UKFTT 415 (TC) (7 April) the FTT directed that HMRC issue closure notices in respect of enquiries into 2018 corporation tax returns averring that it had not met the burden of proof required for the enquiries to be kept open.
The seven applicant companies were members of the Thomson Reuters Group and party to intra-group transactions with Thomson Reuters Global Resources (TRGR) which was tax resident in Switzerland. They sought direction from the FTT that all enquiries be closed. In one case partial closure was requested.
HMRC accepted that closure notices should be issued for the four companies which were not involved in judicial review proceedings.
The remaining three companies had made application for judicial review on the basis that HMRC had misconstrued the effect of an...
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In Refinitiv Ltd and others v HMRC [2025] UKFTT 415 (TC) (7 April) the FTT directed that HMRC issue closure notices in respect of enquiries into 2018 corporation tax returns averring that it had not met the burden of proof required for the enquiries to be kept open.
The seven applicant companies were members of the Thomson Reuters Group and party to intra-group transactions with Thomson Reuters Global Resources (TRGR) which was tax resident in Switzerland. They sought direction from the FTT that all enquiries be closed. In one case partial closure was requested.
HMRC accepted that closure notices should be issued for the four companies which were not involved in judicial review proceedings.
The remaining three companies had made application for judicial review on the basis that HMRC had misconstrued the effect of an...
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:
