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CLOSURE-NOTICE


Card image Catrin Harrison Hugh Gunson Dominic Lawrance
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys) examine an Upper Tribunal decision that is disappointing for taxpayers and removes a strategic weapon for anyone faced with a domicile enquiry.
In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain. 
The tribunal decides it has jurisdiction to determine domicile in closure notice applications. 
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.
 

Wendy Walton and Miranda Chamberlain summarise recent happenings in the private client arena, including changes to the EU Fourth Anti-Money Laundering Directive and extra-statutory concession D33, the new HMRC helpline set up to assist flooding victims, and the business property relief decision in John Best

Adam Craggs and Jonathan Levy on ability to apply for a direction that the tax department issues a closure notice

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