The First-tier Tribunal did not fail to apply the relevant legal principles in determining the taxpayer’s applications for directions that HMRC should issue closure notices in respect of its tax return enquiries. 

Summary 

The First-tier Tribunal (FTT) did not fail to apply the relevant legal principles in determining the taxpayer’s applications for directions that HM Revenue and Customs (HMRC) should issue closure notices in respect of its tax return enquiries. 

Background 

The respondents applied (under TMA 1970, s 28A) to the FTT for closure notices in respect of enquiries by HMRC into the respondents’ self-assessment returns for tax years from 2012/13 to 2019/20.  

HMRC contended that the potential application of the transfers of assets abroad (ToAA) provisions (ITA 2007, Pt 13, Ch 2) needed to be considered in respect of two offshore