Consultation on partial closures of enquires
The government proposes to enable HMRC to refer one or more areas of dispute within a tax enquiry to the Tribunal with a view to achieving early resolution. Any tax found to be due by the Tribunal in respect of the referred matter would become payable, whilst other aspects of the tax enquiry would remain open.
It is envisaged that the enquiry process will work as now until the “joint referral” to the Tribunal, subject to a 30 day appeal period.
If HMRC were ultimately successful a “Tribunal referral closure notice” would be issued and tax would be payable.
The document says that this will allow HMRC to seek swifter resolution of certain aspects of an enquiry.
The real problem seems to be that there is no comparable taxpayer power.
Date: 21st January, 2015
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