[2016] UKFTT 0558 (TC)

[The appeal against this decision is reported at [2017] BTC 530.]

Judge Amanda Brown

Decision released 8 August 2016

Stamp duty land tax – Application for issue of a closure notice – Whether HMRC reasonably required disclosure prior to closure.

  Closure notices in respect of enquiries into SDLT returns were refused where the taxpayers had not provided the documentation requested by HMRC, notwithstanding HMRC were aware of the nature of the planning scheme undertaken by the taxpayers and had, through the issue of settlement invitation letters to them, previously taken the view that their planning did not succeed.

Summary

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