TC09639 - [2025] UKFTT 01113 (TC)

Fecha: 28-Ago-2025

Issues

Issues:

15.

The following issues arise:

(1)

Whether a party, in this case HMRC, is entitled to rely on documents in proceedings that it has not included in its LOD;

(2)

If not, what sanction (if any) is appropriate; and

(3)

Whether the Tribunal should admit the Disputed Documents.

16.

However, before addressing these issues it is convenient to first set out the relevant procedural rules and some judicial observations on their application and the admission of evidence.

Heading
Introduction
Background
Issues
Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009
Whether party entitled to rely on documents not included in its list of documents
Sanction
Whether to Admit Disputed Documents?
Conclusions