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Court of Appeal decides HMRC has no power to issue a partial closure notice in respect of a remittance basis claim without specifying the increased tax due (Embiricos v HMRC)

Published on: 18 January 2022
Published by: LexisPSL
  • Court of Appeal decides HMRC has no power to issue a partial closure notice in respect of a remittance basis claim without specifying the increased tax due (Embiricos v HMRC)
  • Why it matters
  • Case details

Article summary

Tax analysis: In Embiricos v HMRC, the Court of Appeal upheld the Upper Tribunal’s decision that HMRC had no power to issue a partial closure notice in respect of the taxpayer’s domicile and remittance basis claim without specifying the increased tax due as a result. or take a trial to read the full analysis.

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