HM Revenue & Customs v Applicants in the Post Prudential Closure Notice Applications Group Litigations & anr

Tuesday 21 – Friday 24 January 2024

Both parties appeal the decision of Mr Justice Richard Smith and Judge Jonathan Cannan, sitting in the Upper Tribunal (Tax and Chancery Chamber), with judgment delivered on 25 January 2024.

These appeals concern the validity of claims in relation to foreign tax on overseas dividend income received by various investment funds and an insurance company. One group of appeals relates to applications made by some of the Taxpayers to the First-tier Tribunal (“the FTT”) for directions that HMRC should issue closure notices in relation to open enquiries. The other group relates to appeals against closure notices and decisions of HMRC refusing to make repayments of tax.

View hearing:

Day 1

Part 1

Part 2

Day 2

Part 1

Part 2

Day 3

Part 1

Day 4

Part 1

Part 2