TC09583 - [2025] UKFTT 00865 (TC)

As indicated, this is the first case concerning the SDIL regime. We are indebted to the parties and their representatives for their clear and careful submissions and their willingness to take the us through the terms of the legislation. We set out below a summary of the arguments and analysis presented to us; however, we confirm that we carefully considered the skeleton arguments and reviewed our notes of oral submissions made in reaching our decision and preparing this judgment.