Readers’ forum: Should I apply to HMRC for a closure notice?

My client has been involved in a long running technical dispute with HMRC over whether a particular transaction is caught under the Ramsay principle – the details are not relevant here.

The dispute is going nowhere at the moment and has got stuck in endless rounds of correspondence which don’t progress matters. It seems that the only way forward is to apply to the tribunal for the issue of a closure notice. I am nervous about this because anecdotally I have heard that this will only harden HMRC’s position and lead to a closure notice which gives the worst possible outcome for my clients.

I would be interested in hearing from readers about their experiences in applying for closure notices and whether in fact it was of benefit to their clients in the long run.

Query 20 268 – Prevaricator.

The reality is that HMRC has already reached a...