All or nothing

Rebecca Sheldon reviews a judgment on when a partial closure notice can be issued

Judge Robin Vos and Helen Myerscough recently found in favour of the taxpayer in Embiricos v Revenue and Customs Commissioners [2019] UKFTT 236 (TC) (‘Embiricos’), a case concerning when a partial closure notice can be issued. Permission to appeal has been granted.  


Mr Embiricos considered himself to be non-UK domiciled (being originally from Greece but having lived in the UK for many years, before moving to Monaco in 2017). As a result, he had claimed the remittance basis of taxation. HMRC opened enquiries into Mr Embiricos’s self-assessment returns for the years ending 2015 and 2016 and concluded that his domicile was instead England and Wales for the relevant years.