Upper Tribunal Tax and Chancery Chamber

UT (Tax & Chancery) UT-2024-000024 - [2025] UKUT 00156 (TCC)

Fecha: 18-Mar-2025

Outline of HMRC’s case

37.

Mr Elliott for HMRC submitted that the FTT properly interpreted and applied the law, and arrived at the right conclusion. The reasonable recipient would be in no doubt that the letters sent to the Appellants in June 2011 were notices of enquiry into Return A and Return C. The closure notices in respect of those enquiries were therefore valid.

Heading
INTRODUCTION
ENQUIRY APPEAL
A closure notice must either—
A closure notice takes effect when it is issued.”
The FTT Decision
The FTT’s conclusion on the validity of the enquiry notices
Overview of the parties’ cases
Outline of HMRC’s case
Discussion and Analysis
Ground 2 – Notices of enquiry were ambiguous
Section 83(2) FA 2003
THE ASSESSMENT APPEAL
The Legislation
This section applies where–
Where this section applies–
The effective date of the notional transaction is–
Notifiable Transactions
A land transaction is notifiable if it is–
Assessments
Conclusions