HMRC was directed to issue a tax return enquiry partial closure notice after the First-tier Tribunal held that such a notice could be issued in relation to the taxpayer’s domicile/remittance basis claim without specifying the amount of tax due.  
 
The appellant, who was originally from Greece, lived in the UK for many years before moving to Monaco in March 2017. He considered himself to be domiciled outside the UK and had claimed the remittance basis of taxation. 
 
HM Revenue and Customs (HMRC) opened enquiries into the appellant’s self-assessment returns for the tax years 2014/15 and 2015/16 in relation to his claim to be non-UK domiciled. HMRC concluded that the appellant was domiciled in England and Wales during the relevant tax years. 
 
The appellant wished to appeal against HMRC’s decision that he was domiciled in England and Wales, but unless HMRC agreed to