In HMRC v Epaminodas Embiricos [2020] UKUT 0370, the Upper Tribunal (UT) confirmed that HMRC cannot issue a partial closure notice which does not quantify the amount of tax due.

HMRC appealed to the Upper Tribunal on the basis that the FTT had made an error of law.

The UT considered that:

The UT confirmed that a PCN must quantify tax due and allowed HMRC's appeal.

Useful guides on the topic

Closure notices 
When does HMRC issue a closure notice? What is a partial closure notice? Can a taxpayer demand one? Are there appeal rights? 

Non-domicile status, deemed domicile & tax
Who is non-UK domiciled? What does this mean for UK Income Tax, Capital Gains Tax and Inheritance Tax? What reliefs are available to non-doms?

Schedule 36 information notices
What is a Schedule 36 Information Notice? When can HMRC issue one? What rights does the taxpayer have when an information notice is issued?

External link

HMRC v Epaminodas Embiricos [2020] UKUT 0370


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