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Back to basics: Closure notices and the appeals process

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Taxpayers can seek a direction from the FTT requiring HMRC to issue a closure notice within a specified period; the presumption being that an application should be granted unless HMRC can demonstrate that there are reasonable grounds to refuse the application. Once the closure notice is issued by HMRC the taxpayer has a right of appeal should they disagree with HMRC’s conclusion by first making an appeal to HMRC within 30 days of the date of the decision. HMRC must then notify the taxpayer of its view of the matter in question within 30 days and has normally 45 days in which to notify the taxpayer of the conclusions of its review. If the taxpayer wishes not to be bound by this they can appeal to the FTT within 30 days of the ‘post-review period’. Any interest and penalties for late payment may become payable if the...

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