TC09638 - [2025] UKFTT 01112 (TC)

HMRC accepts these are relevant. I have addressed the point about undertaking a further search above.

The Tribunal directs HMRC to undertake a further reasonable search to locate any outstanding documents in these categories and to make disclosure by way of an Amended List of Documents.

Disclosure is to be made of documents whether or not those documents are to be relied on by HMRC, and whether or not they support HMRC's case.

I am aware that the provision as to 'adverse' documents is a departure from the usual Rule. However, as discussed above, I do have doubt as to the overall integrity of the exercise which has been conducted, and it seems to me fair and just that the Appellants should see documents, even if HMRC does not intend to rely on them and/or HMRC regards those documents as adverse to its case.