CLOSURE-NOTICE

SDLT assessment and closure notice: The Wool House Ltd v HMRC [2024] UKFTT 997 (TC) (30 October) is quite an administrative tangle. The taxpayer paid SDLT on the normal single-property basis but then put in an overpayment relief claim, on the basis...

Amortisation of goodwill: Although Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is...

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) provide a refresher guide.

Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...

Mixed-use SDLT appeal failed

Capital allowances on camping pods.

Disregarding carry-back loss claim in closure notice appeal.

Sophie Rhind

Victoria Braid

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.

Jon Preshaw

Craig Thomson

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.