Three brothers who inherited RHG were arguing for closure notices from HMRC to be issued regarding a £40m payment who HMRC believed were beneficiaries of.

Jonathan Hitchins, Jeremy Hitchins and Stephen Hitchins were the respondents in this case where HMRC appealed the decision of the First Tier Tribunal. Unfortunately, Stephen passed away before the tribunal and an executor represented him.

The tax years in question for Jeremy and Jonathan were three years 2017/18, 2018/19, and 2019/20. Enquiries opened into Stephen’s tax returns spanned eight years from 2012/13 to 2019/20.

Closure notices had not been issued in this case – the matter before the FTT was an application from the brothers for a direction that HMRC issue closure notices.