The case of Ebuyer v HMRC shows the FTT taking a tough approach to HMRC’s failure to comply with an unless order requiring the disclosure of documents, resulting in HMRC being barred from proceedings. The taxpayers’ ability to apply for specific directions for disclosure is an important strategic step in the context of the relatively limited disclosure obligations in the FTT. Taxpayers will be reassured by the strict approach taken by the FTT when HMRC fails to comply with directions for specific disclosure. Ultimately, the decisions serves as a reminder of the importance of respecting disclosure obligations.
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The case of Ebuyer v HMRC shows the FTT taking a tough approach to HMRC’s failure to comply with an unless order requiring the disclosure of documents, resulting in HMRC being barred from proceedings. The taxpayers’ ability to apply for specific directions for disclosure is an important strategic step in the context of the relatively limited disclosure obligations in the FTT. Taxpayers will be reassured by the strict approach taken by the FTT when HMRC fails to comply with directions for specific disclosure. Ultimately, the decisions serves as a reminder of the importance of respecting disclosure obligations.
If you are not a subscriber, subscribe now to read this content.
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