The Upper Tribunal have granted permission for the taxpayer to appeal their decision in HMRC v Embiricos [2020] UKUT 370 (TCC), in which they decided that a partial closure notice could not be issued on the question of a taxpayer’s domicile. The case, which has wide-ranging importance for both taxpayer rights and HMRC’s procedure for resolving preliminary issues, will now proceed to the Court of Appeal.
The Appellant is represented by James Kessler QC and Ross Birkbeck, of Old Square Tax Chambers.
