TC09625 - [2025] UKFTT 01066 (TC)

I direct that HMRC disclose the information and documents which complies with the direction attached as an Appendix to this Decision. This is in the same form as that given in Smart Price, but with the addition of particular specific matters identified by Mr Thornton from HMRC documents already disclosed. The directions are made under Tribunal Rules 5(1) and 5(3)(d) and are in accordance with the overriding objective at Rule 2.

This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to "Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)" which accompanies and forms part of this decision notice.