CLOSURE-NOTICE

Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...

Mixed-use SDLT appeal failed

Capital allowances on camping pods.

Disregarding carry-back loss claim in closure notice appeal.

Sophie Rhind

Victoria Braid

Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal will exercise its power to direct HMRC to issue a closure notice in light of the recent case of Hitchins.

Craig Thomson

Jon Preshaw

Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.

Mike Lane

Zoe Andrews

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Catrin Harrison, Dominic Lawrance, Hugh Gunson

Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys) examine an Upper Tribunal decision that is disappointing for taxpayers and removes a strategic weapon for anyone faced with a domicile enquiry.

Nick Clayton

Dawen Gao

In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain.