TC09625 - [2025] UKFTT 01066 (TC)

By the Application, UWG asked for a direction that HMRC provide, in relation to Brands/GB and “those persons identified by HMRC as forming part of the backwards supply chains”: details of seizures, premises known or suspected to be occupied; assessments to excise duty; copies of meeting notes and visit reports; progress reports and/or other contact logs; copies of internal meeting notes, and details of any criminal prosecutions. During the hearing, Mr Thornton amended the Application to include VAT assessments as well as excise duty assessments.

As recorded at the beginning of this decision, Mr Thornton said that UWG would instead be content with a direction similar to that given in Smart Price, ie for HMRC to give what corresponds to standard disclosure under the CPR but with the Namli qualification. However, he drew attention to various documents he had already identified from the HMRC material already supplied, which had not as yet been disclosed to UWG.

I asked Mr Mciver if HMRC would be content with a direction similar to that in Smart Price, but was informed that HMRC remained opposed to any direction.