PAD Fisher v HMRC (and related appeals)

In PAD Fisher v HMRC (and related appeals) (TC02021 – 13 June) a UK company sold a ‘telebetting’ business to an associated Gibraltar company. HMRC assessed the shareholders on the basis that there had been a transfer of assets abroad within what is now ITA 2007 ss 714–751. The shareholders appealed and applied for disclosure of various documents held by HMRC. The First-tier Tribunal rejected the application with regard to the majority of the documents in issue but allowed the application with regard to correspondence and notes of meetings with the Betting Office Licensees Association. Judge Mosedale observed that the shareholders were engaged in ‘a fishing exercise to catch fish that are most unlikely to be of any interest to the tribunal hearing the substantive appeal’. (The Tribunal also rejected an application by HMRC that the shareholders...