TC09548 - [2025] UKFTT 00700 (TC)

On 8 March 2024, HMRC issued the Appellant with determinations totalling £96,037,893 for the tax years 2017-18 through to 2019-20 (“the Determinations”). HMRC did not include any reasons in the text of the Determinations, or in the covering correspondence.

The Appellant appealed the Determinations to the Tribunal, and HMRC applied for the Appellant to provide further and better particulars of its grounds of appeal (“the F&B Application”). I refused the F&B Application in a case management decision issued on 5 March 2025 (“the First Decision”).

HMRC issued its Statement of Case (“SoC”) on 26 March 2025. The SoC did not give reasons for the Determinations. On 2 April 2025, the Appellant applied for HMRC properly to particularise its SoC (“the SoC Application”). On 17 April 2025 I allowed that Application by a second case management decision and issued Directions to HMRC (together, “the Second Decision”).

On 30 April 2025, on behalf of HMRC, Mr Joshua Carey and Mr Sam Way, both of Counsel, applied for permission to appeal against the First and Second Decisions (“the PTA Application”). This is my decision refusing the PTA Application.