[2016] UKUT 0105 (TCC)

Upper Tribunal (Tax and Chancery Chamber)

Mrs Justice Rose, Chamber President

Decision released 1 March 2016

Corporation tax – Finance Act 1998 (‘FA 1998’), Sch. 18, para. 33 – Application for closure notice – Discovery assessment made before enquiry opened – Settled by agreement – under Taxes Management Act 1970 (‘TMA 1970’), s. 54 – Effect of settlement on scope and possible conclusions of enquiry – Scorer (HMIT) v Olin Energy Systems Ltd [1985] BTC 181 considered – Reasonableness of continuing enquiry.

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