The recent decision in MJP Media highlights the difficulties of persuading a court of appeal to interfere, where the First-tier Tribunal has made findings of fact on the available and limited evidence. Liesl Fichardt identifies the lessons for taxpayers.
In an ideal and perfect world a corporate taxpayer faced with litigation in the tribunal would be able to provide a complete set of documents relevant to the issue to be determined. Even should the issue relate to a tax period many years ago it would have available to it as witnesses all individuals who could testify first hand as they were present at the relevant time drafted the particular documentation and would be able to explain the nature of the transaction ...
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