In recent months, HMRC appears to have been more amenable to resolving disputes by way of alternative dispute resolution, and the ADR process itself has adapted well to virtual mediations necessitated by the covid pandemic restrictions. In an important (and in the authors’ view, questionable) ruling in Embiricos, the Upper Tribunal held that HMRC could not be compelled to issue a partial closure notice denying the taxpayer’s claim to the remittance basis without specifying the amount of tax due. Finally, HMRC seems more inclined to seek specific disclosure of documents and to request further and better particulars of a taxpayer’s grounds of appeal in circumstances where it is already well-aware of the taxpayer’s case, although such a request was recently refused by the FTT in Bradford.
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 recent months, HMRC appears to have been more amenable to resolving disputes by way of alternative dispute resolution, and the ADR process itself has adapted well to virtual mediations necessitated by the covid pandemic restrictions. In an important (and in the authors’ view, questionable) ruling in Embiricos, the Upper Tribunal held that HMRC could not be compelled to issue a partial closure notice denying the taxpayer’s claim to the remittance basis without specifying the amount of tax due. Finally, HMRC seems more inclined to seek specific disclosure of documents and to request further and better particulars of a taxpayer’s grounds of appeal in circumstances where it is already well-aware of the taxpayer’s case, although such a request was recently refused by the FTT in Bradford.
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:
