HMRC has also published a summary of the responses it received to its consultation document on its proposals to enable HMRC to close specific issues within a tax enquiry in order to enable that issue to be determined by the Tribunal. There was overwhelming objection to the proposal that only HMRC would be able to make partial closure referrals to the Tribunal. The majority of respondents expressed the view that taxpayers should also be able to make such referrals to the Tribunal. This is the view RPC expressed when submitting its response to the consultation document.

Some respondents also felt that such a power was unnecessary and that proposed safeguards were too weak.

HMRC has said that it will develop alternative models and will consult further. It has indicated that the intention was to include new rules in the Finance Bill 2016, however, it accepted that this may be deferred until 2017.

The Summary of Responses can be read here.