HMRC v The taxpayer

In HMRC v The taxpayer [2024] UKUT 12 (TCC) (11 January 2024) the Upper Tribunal (UT) upheld HMRC’s appeal against the FTT case management direction that preliminary proceedings in the taxpayer’s appeal should be heard in private.

The taxpayer appealed to the FTT against HMRC’s decision to deny him deductions for income tax purposes. The deductions which had been claimed were said to arise in relation to arrangements which had been challenged by HMRC and which were the subject of two other lead cases. The taxpayer also applied to the FTT that his appeal be heard in private and the judgment be anonymised. The taxpayer claimed this was necessary to protect his private life maintain the confidentiality of sensitive information and to avoid prejudice to the interests of justice.

The FTT issued directions that preliminary proceedings in the appeal should be heard in private (Direction 3) and that shortly...

If you are not a subscriber, subscribe now to read this content.

If you are already a subscriber, sign in

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this article in full.