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What constitutes a valid closure notice? A review of the Court of Appeal’s recent decision in CRC v Bristol and West plc.
KEY POINTS
- HMRC withdrew an erroneously issued closure notice which it claimed was not valid.
- A closure notice must state HMRC has completed the enquiry and give its conclusions.
- Further debate negotiation and settlement can take place.
- The extent to which each party is bound by the closure notice regime is unclear.
The procedural requirements for issuing a valid closure notice in relation to an HMRC enquiry have been considered by a higher court for the first time in CRC v Bristol and West plc [2016] EWCA Civ 397. But it raises a number of intriguing questions some of which remain unanswered.
The Court of Appeal exhaustively analysed the process within the meaning of FA 1998 Sch 18 para 32. Faced with a dearth of direct judicial authority on the subject ...
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