TC09514 - [2025] UKFTT 00524 (TC)

Fecha: 25-Abr-2025

The Rules

The Rules

12.

Under Rule 2 of the First-tier Tribunal (Tax Chamber) Rules 2009 (as amended) (“theRules”):

Overriding objective and parties’ obligation to co-operate with the Tribunal

(1)

The overriding objective of these Rules is to enable the Tribunal to deal with cases fairly and justly.

(2)

Dealing with a case fairly and justly includes—

(a)

dealing with the case in ways which are proportionate to the importance of the case, the complexity of the issues, the anticipated costs and the resources of the parties;

(b)

avoiding unnecessary formality and seeking flexibility in the proceedings;

(c)

ensuring, so far as practicable, that the parties are able to participate fully in the proceedings;

(d)

using any special expertise of the Tribunal effectively; and

(e)

avoiding delay, so far as compatible with proper consideration of the issues.

(3)

The Tribunal must seek to give effect to the overriding objective when it—

(a)

exercises any power under these Rules; or

(b)

interprets any rule or practice direction.

(4)

Parties must—

(a)

help the Tribunal to further the overriding objective; and

(b)

co-operate with the Tribunal generally.

13.

Under Rule 20, proceedings must be started by sending a notice of appeal to the tribunal and under Rule 20(3) “The appellant must provide with a notice of appeal a copy of any written record of any decision appealed against, and any statement of reasons for that decision, that the appellant has or can reasonably obtain”.

14.

Furthermore, under Rule 20(4), if a notice of appeal is provided after the 30 day time limit, but the relevant legislation provides that an appeal may be made or notified after that time with the permission of the tribunal, then the notice of appeal must include a request for such permission and the reason why the notice of appeal was not provided in time.