TC09625 - [2025] UKFTT 01066 (TC)

In Mr Mciver’s submission, UWG ought instead to have taken steps, at the time it was issued with the assessments, to challenge HMRC’s investigation by way of judicial review. He drew attention to the tight timescale for such a challenge, and said it was “not proper” for UWG now to use the disclosure process “to fill that gap”.

Mr Thornton confirmed that UWG were not seeking to challenge HMRC’s investigation process. He added, entirely correctly, that it was clear from Hughes and Tideswell that judicial review was not the only option, and that the recipient of a duty assessment could ask for disclosure.