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.

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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.

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Published 27 May 2020