Market leading insight for tax experts
View online issue

Embiricos and the future of partial closure notices

Speed read
In Embiricos, the Upper Tribunal considered whether HMRC can be compelled to issue a ‘partial closure notice’ regarding a taxpayer’s domicile, which can be appealed by the taxpayer, without HMRC having the information to allow them to determine the additional tax at stake. The UT found in HMRC’s favour, concluding that a taxpayer must provide information regarding his foreign income and gains before HMRC is obliged to issue any closure notice regarding domicile. The decision is disappointing for taxpayers and, subject to any appeal, removes a powerful strategic weapon for anyone faced with a domicile enquiry.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.