TC09548 - [2025] UKFTT 00700 (TC)

Fecha: 09-Jun-2025

Directions

Directions

75.

Having considered the draft Order put forward by the Appellant, together with the information in the Bundle and that in the SoC, I directed that HMRC explain:

(1)

why they consider some or all of LLP members do not fail Condition A, and if so which members and why;

(2)

why they consider some or all of the LLP members do not fail Condition C, and if so, which members and why;

(3)

whether they consider some or all of the LLP members do not fail Condition B, and if so, which members and why;

(4)

the basis on which they calculated the amounts assessed in the Determinations;

(5)

whether they had considered the interaction with the tax paid by LLP members via self-assessment; and

(6)

by reference to specific facts, the basis on which they decided that the Appellant acted either carelessly or deliberately in relation to 2017-18 and 2018-19.

76.

I then said that when HMRC had complied with these Directions, I would consider whether a case management hearing was required further to clarify the position. I did not link compliance with the Directions to a barring order, as the Appellant had requested.