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Back to basics: HMRC enquiries and obtaining closure

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The ability to apply for a direction that HMRC issue a closure notice is an important safeguard that parliament saw fit to provide to taxpayers, and one which should not be overlooked by taxpayers who find themselves frustrated by HMRC’s unwillingness to bring an enquiry to an end. There is a presumption that such an application should be granted by the tribunal unless HMRC is able to demonstrate, on a balance of probability, that there are reasonable grounds to refuse it. The Supreme Court judgment in Tower MCashback 1 LLP examines the issues of what should or should not be included in a closure notice.

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