TC09574 - [2025] UKFTT 00852 (TC)

I have set out the relevant provisions of the TMA in the Appendix.

The relevant Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (as amended) (the “Rules”) are Rules 2 and 8:

Rule 2(3) requires us to give effect to the over-riding objective when exercising any power under the Rules. The over-riding objective, as set out in Rule 2(1), is as follows:

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

Rule 8 deals with strike out. Under Rule 8(2)(a):

“The Tribunal must strike out the whole or part of the proceedings if the Tribunal-

(a)

does not have jurisdiction in relation to the preceding or that part of them;…”.