In Cider of Sweden Ltd v HMRC v Ernst & Young LLP [2022] UKFTT 76 (TC) (18 February 2022) the FTT dismissed EY's application for disclosure to them of various documents (such as the notice of appeal HMRC's statement of case and any further pleadings) brought into existence in the context of the main tax proceedings between another taxpayer Cider of Sweden and HMRC. This was because EY had made the application when the main proceedings were at a very early stage because the hearing had not yet been listed and was not even likely to occur in the near future i.e. the application was made before any substantive judicial involvement. The public interest here was not sufficient to displace the principle that until a case has been heard the taxpayer is entitled to privacy. Readers may recall a similar case last year – JTI...
