The Commissioners for HM Revenue and Customs v Invercylde Property Renovation LLP and Clackmannanshire Regeneration LLP: [2020] UKUT 0161 (TCC)
Upper Tribunal Tax and Chancery decision of Lord Tyre and Judge Raghavan on 27 May 2020.
Read the full decision in .
INCOME TAX –– limited liability partnerships – Income Tax (Trading and Other Income) Act 2005, section 863 – whether HMRC had power to open enquiry under Taxes Management Act 1970, section 12AC – whether any enquiry should have been made under Finance Act 1998, Schedule 18, paragraph 24 – whether closure notices issued under Taxes Management Act 1970, section 28B were valid – yes – appeal allowed.
Published 27 May 2020