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Partial closure notices
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Partial closure notices
PARTIAL-CLOSURE-NOTICES
The other Greek case: Embiricos reaches the Court of Appeal
Dominic Lawrance
Catrin Harrison
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine the Court of Appeal’s decision on partial closure notices in respect of domicile cases.
Contentious tax quarterly
Constantine Christofi
Adam Craggs
HMRC seems more amenable to alternative dispute resolution, whilst also pushing for greater formality in tax appeals, report Adam Craggs and Constantine Christofi (RPC).
Embiricos and the future of partial closure notices
Dominic Lawrance
Hugh Gunson
Catrin Harrison
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.
Closing HMRC enquiries
Craig Thomson
We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
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HMRC step up VAT scrutiny as large and medium sized-business investigations rise 31%
Government announces increase to Electricity Generator Levy
CIR returns
HMRC issue updated VAT road fuel scale charges
CCA scheme extended to new sectors and updated guidance issued
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Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
Centrica Energy Storage Ltd v HMRC
Clearwater Hampers Ltd v HMRC
Other cases that caught our eye: 24 April 2026
CATS North Sea Ltd v HMRC
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IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
ATED: a reminder
UK short-term business visitors: the Appendix 4 report
Tax advisers: sanctionable conduct
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Tax advisers: sanctionable conduct
Section 171A elections
HMRC loans to participators tool
Mega Marshmallows and the meaning of ‘normally’
Centrica Energy Storage Ltd v HMRC