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PROCEDURE - application for an issue to be determined at preliminary hearing - Wrottesley v HMRC considered - application refused
For the Appellant:�������� Kevin Prosser KC and Barbara Belgrano, counsel, instructed by Moore Family Office Limited, chartered accountants
For the Respondents: �� Sebastian Purnell, counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs
             By way of background, HMRC opened enquiries into Mr Embiricos� UK tax returns for 2014/15 (opened on 1 December 2016) and 2015/16 (opened on 28 November 2017). The principal focus of HMRC's enquiries has been whether Mr Embiricos was entitled to be taxed on the remittance basis. It is not disputed that Mr Embiricos has a Greek domicile of origin, however HMRC assert that he has acquired a domicile of choice within the UK and is therefore ineligible to use the remittance basis of taxation.
             On 13 June 2018 Mr Embiricos applied to this Tribunal for a final closure notice in respect of the 2014/15 enquiry. This application was subsequently amended to an application for a partial closure notice ("PCN") in respect of Mr Embiricos� domicile status.
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