Adam Craggs and Alexis Armitage (RPC) consider the new proposed legislation, which will enable partial closure notices to be issued in respect of a discrete issue, while other issues remain under enquiry by HMRC.
Before considering the proposed changes contained in the draft Finance Bill 2017 which will enable HMRC to issue partial closure notices (PCNs) in respect of a discrete issue while other issues remain under enquiry by HMRC it may be helpful to remind ourselves of the current position.
The enquiry process
HMRC may enquire into any tax return made by an individual a trustee or a partnership (TMA 1970 ss 9A and 12AC) or a company (FA 1998 Sch 18 para 24(1)). An enquiry may be commenced as a result of HMRC’s scrutiny of a tax return or on the basis of information held by HMRC.
Completion of an...
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Adam Craggs and Alexis Armitage (RPC) consider the new proposed legislation, which will enable partial closure notices to be issued in respect of a discrete issue, while other issues remain under enquiry by HMRC.
Before considering the proposed changes contained in the draft Finance Bill 2017 which will enable HMRC to issue partial closure notices (PCNs) in respect of a discrete issue while other issues remain under enquiry by HMRC it may be helpful to remind ourselves of the current position.
The enquiry process
HMRC may enquire into any tax return made by an individual a trustee or a partnership (TMA 1970 ss 9A and 12AC) or a company (FA 1998 Sch 18 para 24(1)). An enquiry may be commenced as a result of HMRC’s scrutiny of a tax return or on the basis of information held by HMRC.
Completion 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:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")