In the recent case of Hitchins, the FTT directed HMRC to issue a closure notice on the basis that outstanding information requests were not sufficiently relevant and therefore did not form a reasonable basis for keeping the enquiry open. In particular, there was no evidence that HMRC reasonably believed the query would actually yield relevant information. Advisers should consider this approach when analysing the merits of HMRC’s information requests and considering whether there is evidence that such requests will yield relevant information. Refusing to provide the information requested by HMRC will not be fatal to an application for a closure notice where there is no reasonable basis upon which the information has been requested.
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:
In the recent case of Hitchins, the FTT directed HMRC to issue a closure notice on the basis that outstanding information requests were not sufficiently relevant and therefore did not form a reasonable basis for keeping the enquiry open. In particular, there was no evidence that HMRC reasonably believed the query would actually yield relevant information. Advisers should consider this approach when analysing the merits of HMRC’s information requests and considering whether there is evidence that such requests will yield relevant information. Refusing to provide the information requested by HMRC will not be fatal to an application for a closure notice where there is no reasonable basis upon which the information has been requested.
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)
