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HMRC consults on new power for closures of single aspect of tax enquiries

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As announced at Autumn Statement, HMRC is now consulting until 12 March 2015 on a new power, enabling HMRC to achieve early resolution and closure, including payment, in respect of one or more aspects of a tax enquiry, whilst leaving other aspects of the tax enquiry open.

In this week’s Tax Journal, James Bullock (Pinsent Masons) writes that the proposals would lead to ‘a staggering “inequality of arms”, giving HMRC an overwhelming advantage in terms of being able to control legal precedent’, adding that: ‘The requirement for authorisation by a senior HMRC officer and the right of appeal against a tribunal referral notice are unlikely to provide comfort’.