Lyle & Scott and others v HMRC

In Lyle & Scott and others v HMRC [2017] UKFTT 137 (1 February 2017) the FTT refused an application for costs when HMRC had issued closure notices only six days before the hearing of the application for such notices.

This was an application for the tribunal to award costs on the ground that HMRC had acted unreasonably in proceedings. Lyle & Scott had applied to the tribunal for a direction that HMRC issue closure notices but six days before the date listed for the hearing HMRC issued the closure notices.

The FTT set out to answer the three questions set out by the UT in Tarafdar [2014] UKUT 362.

• What was the reason for the withdrawal of HMRC from the appeal?

The FTT found that HMRC had finally received the information which had been requested by notice and had applied it in...