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Changes to applying for permission to appeal

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When does a winning party need to apply for permission to appeal (PTA) to raise new issues at the Upper Tribunal (UT) in response to an appeal to the UT by the losing party? In SSE, the Court of Appeal had determined that a respondent to an appeal in the UT could not raise an issue which it lost unless it obtained permission to appeal (PTA) from the FTT. However, following a change to rule 24 of the UT rules, parties can now seek PTA in response to the other side’s appeal. Furthermore, following the UT’s decision in HBOS, PTA will only be necessary at all (i.e. rather than raising arguments in response) if taxpayers seek to ‘do better’ than the original decision.

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