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Summer 2020 review

1. Amrolia: clarity on getting closure 

In R (on the application of Amrolia) v HMRC; R (on the application of Ranjit-Singh) v HMRC [2020] EWCA Civ 488 (reported in Tax Journal 17 April) the Court of Appeal found that notices amending individual partners’ tax returns under TMA 1970 s 28B(4) were not closure notices and therefore did not need to specify the final amounts of tax due. 

Why it matters: Although partnerships (including in most cases LLPs) are not taxable in their own right they must submit tax returns. If HMRC wishes to enquire into a partnership tax return it may do so under TMA 1970 s 12AC. Upon closure of the enquiry HMRC must deliver a closure notice to the partnership and must give effect to the closure notice by serving notices on the partners (under s 28B(4)) to amend...

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