TC09643 - [2025] UKFTT 01117 (TC)

We were provided with a bundle of documents comprising 670 pages (as accepted by Mr de Haan, many of which were duplicated chains of emails) and witness statements from Mr Alexander Marsden (on behalf of the Appellant) and Mr Steven Mack (on behalf of HMRC). Mr Mack’s statement was accepted, and while Mr Marsden was subject to cross-examination, there was no substantive dispute with his evidence.

In this appeal, the Appellant bears the burden of proving that the Assessments overstate its liability to RGD. They must do so on the balance of probabilities.

From that evidence, we are able to find the following facts, which we split into two sections: the facts concerning the operation of the Mega Reel and those concerning Assessment 3.