Tabassum Khan, Associate in Mishcon de Reya’s Tax Litigation and Dispute Resolution department, and Timothy Folaranmi, Managing Associate and Professional Support Lawyer in Dispute Resolution, have written an article in AccountingWEB, entitled: “When can HMRC partly close down a tax enquiry?”
Following the recent case of Embiricos v Revenue and Customs Commissioners, which involved a domicile status enquiry by HMRC, the article takes a closer look at the circumstances in which HMRC can now issue (or be required to issue) a Partial Closure Notice ("PCN"), to a taxpayer whose return is under enquiry.
The piece also considers what the case’s resulting judgement means for the rights of all taxpayers, in conjunction with HMRC's ability to issue information notices.
Read the full article: When can HMRC partly close down a tax enquiry?