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