17 March 2022
Redevco Properties UK 1 Ltd v HMRC; (FTT)
The appellant made an application for the Tribunal to amend the closure notice under appeal during the proceedings (rather than at the end of the proceedings) to take account of a concession made by HMRC in its statement of case. HMRC resisted that application on the grounds that the Tribunal had no jurisdiction to exercise its powers under section 50 Taxes Management Act 1970 prior to the final determination of all of the issues in the appeal. The Tribunal agreed with HMRC and held that the Tribunal must made a single, final decision following a substantive hearing at which the appeal is determined. The Tribunal did, however, make a formal debarring order in relation to the issue conceded by HMRC.