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Finnforest UK Ltd v HMRC (and related appeals)

In Finnforest UK Ltd v HMRC (and related appeals) (TC01202 – 10 June) HMRC began enquiries into the returns submitted by a company (F) which had made claims for cross-border group loss relief. In May 2010 F applied for closure notices.

The First-tier Tribunal reviewed the evidence in detail and dismissed the applications. Judge Kempster observed that F’s international group structure was complicated and had varied over different accounting periods.

Accordingly it was ‘reasonable that HMRC should need to gather detailed information on specific points they require to be clarified’.

Why it matters: FA 1998 Sch 18 para 33 provides that a company which is subject to an HMRC enquiry may apply for a direction for a ‘closure notice’.

On the facts here the Tribunal rejected the companies’ applications finding that HMRC had ‘reasonable grounds...

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