Closure notice application succeeds

The taxpayer was a chartered accountant. HMRC opened an enquiry into his 2014-15 tax return. Several matters were raised but the only one that remained open related to licence fees received from the taxpayer’s personal company.

An enquiry was opened into the next year’s return by reference to the same point. HMRC was concerned that the licensing arrangement was a National Insurance avoidance device and HMRC referred the matter to several departmental specialists. One internal memo which was disclosed as part of the appeal process read: ‘However the tax advantaged incorporations that the chancellor put a stop to have produced a great deal of correspondence here in Shares and Asset Valuations and we are well used to the kinds of argument that can surface.’

Matters dragged on and a year after the enquiry matters were in the words of the judge ‘drifting along aimlessly’. A further...