Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.
When HMRC enquires into a tax return a key consideration in resolving matters is judging when HMRC is in a position to issue a closure notice. Generally HMRC will wish to understand all of the relevant facts before reaching its conclusions. Inevitably HMRC’s and the taxpayer’s views on the relevance of information and the necessity to provide it before the enquiry can be concluded will often diverge. The law allows a taxpayer to seek the issue of a closure notice by the tribunal as a protection against unduly prolonged HMRC investigations. The recent FTT case of Vitol Aviation Ltd v HMRC [2021] UKFTT 353 (TC) provides useful lessons for both taxpayers and HMRC...
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Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.
When HMRC enquires into a tax return a key consideration in resolving matters is judging when HMRC is in a position to issue a closure notice. Generally HMRC will wish to understand all of the relevant facts before reaching its conclusions. Inevitably HMRC’s and the taxpayer’s views on the relevance of information and the necessity to provide it before the enquiry can be concluded will often diverge. The law allows a taxpayer to seek the issue of a closure notice by the tribunal as a protection against unduly prolonged HMRC investigations. The recent FTT case of Vitol Aviation Ltd v HMRC [2021] UKFTT 353 (TC) provides useful lessons for both taxpayers and HMRC...
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