Jones: Appealing questions of fact

The recent Supreme Court decision in Jones radically redraws the line between the jurisdiction of the First-tier and Upper Tribunals. It gives to the latter an enhanced supervisory role over the decisions of the former. For HMRC and taxpayers, this should promote desirable consistency in decision making. But it will also herald, on the ground and in appropriate cases, a very real relaxation of the limitation on appeals to questions of law.