TC09638 - [2025] UKFTT 01112 (TC)

Fecha: 22-Ago-2025

The Application

The Application

The Appellants request disclosure of five categories of documents, namely:

(1)

Full tax returns and accompanying documents for the relevant tax years, and for the settlements of gains;

(2)

All Forms 41G(Trust) and 50(FS) submitted on behalf of the relevant settlements;

(3)

Correspondence and any enclosed documentation from 6 April 2000 and 31 January 2009, relating to round-the-world planning, passing between HMRC and:

(a)

the Appellants;

(b)

Lansbury's International Ltd (the Appellants' previous representative); and

(c)

any trustees of the relevant settlements.

(4)

Correspondence and any enclosed documentation for that same period referring to any of the Appellants between HMRC and accountants or other representatives;

(5)

"If HMRC contend that they did not believe, in principle that relief under the UK/NZ DTC 1983 and/or the UK/Mauritius DTC ... applied to determine the amount on which the trustees would be chargeable to tax ... any internal HMRC documents that adversely affect HMRC's case or support the Appellants' case including correspondence with the NZ and Mauritian revenue authorities".

They argue that such documents are necessary to establish the factual basis of claims, to assess whether there is any estoppel, and to understand HMRC’s historical position.

10.

Should a direction for disclosure be made, the Applicants also apply for a stay pending compliance with any such direction.