Vaccine Research LLP v Commissioners for Her Majesty's Revenue and Customs

Decision date: 16 October 2009

Neutral citation: [2009] UKFTT 333 (TC)

Overall AI summary confidence: medium

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Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: medium

Vaccine Research LLP asked the Tribunal to direct HMRC to issue a closure notice for the 2006–07 partnership return after HMRC's enquiry into very large capital allowance claims. The Tribunal found HMRC had conducted the enquiry to the point where they could reasonably make an informed judgment, rejected HMRC’s request for three months to pursue further third‑party enquiries, and directed HMRC to issue a closure notice within 45 days of 2 October 2009.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: high

A closure notice need not be lengthy or state detailed reasons; a tax officer may properly issue a closure notice once the enquiry has reached the point where a reasonable, informed judgment can be made. A request for an extended period to complete third‑party enquiries can be refused where the authority concedes it could decide without that additional information.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: high

No clear obiter dicta are identified in the notes beyond references to accepted authorities about the form and sufficiency of closure notices cited by counsel and in earlier judgments.

Warning

This chunk contains duplicated passages of the same text, which may be noisy. This chunk contains duplicated passages and may be noisy; otherwise no other obvious incompleteness noted.