Following an announcement at Autumn Statement 2014, HMRC has issued a consultation on proposals to allow HMRC to refer matters to the tax tribunal in order to speed up the resolution time for certain enquiries into Self Assessment tax returns
The HMRC consultation: Tax Enquiries: Closure Rules, would allow the tax authorities to review certain aspects of an outstanding dispute and resolve these issues, while the wider tax investigation remains open.
According to the consultation document, ‘HMRC would target the power at cases or issues involving significant tax under consideration or involving issues which are novel, complex, or have a wider impact, which can include tax avoidance. The government proposes that HMRC would expect earlier payment of tax in respect of the particular aspects successfully addressed by HMRC’.
The government seeks views on this proposal to reflect the complex nature of contemporary tax affairs and to modernise the administration of the tax system by increasing flexibility.
This consultation proposes changes to the Self Assessment enquiry framework in respect of income tax, including National Insurance Contributions (NICs) Class 2 and 4 in certain circumstances, capital gains tax and corporation Tax.
The consultation is out for comment until 12 March 2015.
The documentation is available here https://www.gov.uk/government/consultations/tax-enquiries-closure-rules