Circumstances in which an officer of the Commissioners for Her Majesty’s Revenue and Customs (‘HMRC’) who is enquiring into a tax return can give (or be required to give) the taxpayer a partial closure notice (‘PCN’). In particular, can HMRC be required to give a PCN when the officer has completed his enquiries into a matter to which the enquiry relates, without quantifying the tax due as a result of the conclusion reached by the officer in relation to that matter? Here, the matter enquired into was whether or not the taxpayer is entitled to claim the benefit of the remittance basis of assessment as a person not domiciled in the UK in the relevant tax years.
Judges:
Lady Justice Nicola Davies
Lady Justice Simler
And
Mr Justice Francis
Citations:
[2022] EWCA Civ 3
Links:
Jurisdiction:
England and Wales
Taxes Management
Updated: 29 January 2022; Ref: scu.671019