Conclusions
Decision
For the reasons set out above the Assessments are upheld save to the extent that they now need to be reduced in light of the information provided by the Appellant on the RGD accounted for on MR Spins.
Right to apply for permission to appeal
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 16th SEPTEMBER 2025
- Heading
- Introduction
- Evidence and findings of fact
- Mega Reel
- Assessment
- Relevant legislation
- The issues
- Liability issue
- Parties’ submissions
- Discussion
- Statutory context of the relevant provisions of Part 3 Chapter 3
- Parties submissions
- Discussion
- Parties submissions
- HMRC’s submissions
- Discussion
- Validity issue
- Discussion
- Conclusions
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