CLOSURE NOTICE TO BE ISSUED WITHIN SET TIME

摘要

In the case of Bloomfield v Revenue & Customs [2013] UKFTT 593 (TC), HMRC opened an enquiry into Mr Bloomfield's affairs in January 2010. Bloomfield applied to the FTT for a direction that the relevant HMRC officer should issue a closure notice within a set time. Under s28A(4)-(6) of the Taxes Management Act 1970, the tribunal has to direct the officer to issue the notice, unless it is satisfied that there are reasonable grounds for not issuing a notice within a specified period. In this case although the evidence provided was brief, the FTT decided that much of the background evidence was not relevant to whether a closure notice should be issued.