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THE WOOL HOUSE LIMITED V HMRC TC/2022/11576 and 2023/00414

In this appeal to the FTT, HMRC sought recovery of an SDLT refund paid to the taxpayer and received by it around the same time as the issue of the closure notice refusing the claim and asking for the refund to be repaid with interest.
The core question for the FTT was whether the requirement on HMRC to issue an assessment of the money due within 30 days after the issue of the closure notice was met when the assessment in this case had been issued on or before the issue of the closure notice.
The FTT applied a purposive interpretation of the relevant rules and held that an assessment made either before or at the same time as the closure notice was valid even though it had not been made within the period of 30 days after the issue of the closure notice.

You can read the decision here.

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