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Embiricos and the future of partial closure notices

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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.

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