Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.
Few case management decisions at the First-Tier Tribunal (‘the tribunal’) are published. It was with particular interest therefore that we saw a whole flurry appear in a single decision in the case of BGC Services Holdings LLP v HMRC [2025] UKFTT 700 (TC).
The dispute arose in the context of an appeal by a taxpayer against a number of HMRC determinations issued without providing reasons or justification. This wide-ranging decision addresses several interesting aspects of tribunal procedure as well as the relationship between HMRC’s statutory and public law duties. It is a revealing treatment of the legal nature and extent of the Commissioners’ obligation to properly particularise determinations of tax liability both outside and inside the tribunal.
Procedural background
Although the case...
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Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.
Few case management decisions at the First-Tier Tribunal (‘the tribunal’) are published. It was with particular interest therefore that we saw a whole flurry appear in a single decision in the case of BGC Services Holdings LLP v HMRC [2025] UKFTT 700 (TC).
The dispute arose in the context of an appeal by a taxpayer against a number of HMRC determinations issued without providing reasons or justification. This wide-ranging decision addresses several interesting aspects of tribunal procedure as well as the relationship between HMRC’s statutory and public law duties. It is a revealing treatment of the legal nature and extent of the Commissioners’ obligation to properly particularise determinations of tax liability both outside and inside the tribunal.
Procedural background
Although the case...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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