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.
Where a tax return addresses complex issues and facts a lengthy enquiry may be inevitable. Frequently however enquiries can seem never-ending. Where discussions between the taxpayer and HMRC cannot progress matters there are limited options open to the taxpayer but the taxpayer can apply to the First-tier Tribunal (FTT) to direct HMRC to close their enquiries. Taxpayers are often reluctant to take this step but the recent case of Hitchins v HMRC [2023] UKFTT 127 (TC) illustrates how the FTT will approach matters and...
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:
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.
Where a tax return addresses complex issues and facts a lengthy enquiry may be inevitable. Frequently however enquiries can seem never-ending. Where discussions between the taxpayer and HMRC cannot progress matters there are limited options open to the taxpayer but the taxpayer can apply to the First-tier Tribunal (FTT) to direct HMRC to close their enquiries. Taxpayers are often reluctant to take this step but the recent case of Hitchins v HMRC [2023] UKFTT 127 (TC) illustrates how the FTT will approach matters and...
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:
13d4b65d-176a-405a-a126-479bca95a2e8.jpg?sfvrsn=b0997f03_1)
