This site uses cookies. By continuing to browse the site you are agreeing to our use of cookies. To find out more about cookies on this website and how to delete cookies, see our privacy notice.

Applications to tribunal for directions that HMRC issue closure notices were upheld

By Mark McLaughlin, December 2021

HMRC had sufficient information to close its enquiries, and the existence of an ongoing diverted profits tax review did not provide reasonable grounds for HMRC refusing to issue closure notices, such that the applicants’ application to the tribunal for directions that HMRC close its enquiries was upheld.

The applicants, members of a corporate group (the Vitol Group), traded globally. The European operations of the Vitol Group were based in Switzerland. The Vitol Group and HM Revenue (HMRC) entered into a unilateral advance pricing agreement (APA) covering the periods 31 December 2010 to 31 December 2015 inclusive. In late 2015, the Vitol Group and HMRC began discussions regarding an APA for the accounting period ending 31 December 2016 onwards. HMRC advised they would

Subscribe to the McLaughlin’s Tax Case Library to get instant access
to the Tax Case Library.
14 day free trial , 90 day money back guarantee
Subscribe

Related or similar articles

Follower notice penalties were properly imposed but reduced on appeal
By Mark McLaughlin, August 2022
Company Was Not Entitled To Compound Interest From HMRC
By Mark McLaughlin, October 2018
Tax Return Enquiry Closure Notice Issued By HMRC In Error Was Invalid
By Mark McLaughlin, August 2016
Penalty Appeal Successful As HMRC Information Notice Was Invalid
By Mark McLaughlin, November 2015
Penalties Due For Errors Resulting In Overstated Losses
By Mark McLaughlin, March 2015