TC09548 - [2025] UKFTT 00700 (TC)

I ended the First Decision with the following conclusion:

“HMRC are required to give reasons for their decisions, as a matter of public law. It is thus not sufficient for HMRC to say, as they now do, that once they have made an assessment, the burden rests on the Appellant, and it is then the Appellant which must provide F&B particulars in relation to the application of the Salaried Member Rules. To use colloquial language, HMRC have made a broad brush decision, and are now asking the Tribunal to assist them in requiring the Appellant to colour in the detail. It is instead for HMRC to set out its position in compliance with Rule 25(2)(b).”