A partial closure notice in an enquiry by HMRC could not be issued in relation to a taxpayer’s claim to the remittance basis without specifying the amount of tax due.

Summary

A partial closure notice in an enquiry by HM Revenue and Customs (HMRC) could not be issued in relation to a taxpayer’s claim to the remittance basis without specifying the amount of tax due.

Background

The taxpayer, 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.

HMRC opened enquiries into the taxpayer’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 taxpayer was domiciled in England and Wales during the relevant tax years.

The taxpayer wished to