TC09682 - [2025] UKFTT 01334 (TC)

Fecha: 13-Ago-2025

Conclusions

Conclusion

27.

I consider it to be appropriate and in the interests of fairness and justice for this appeal to be stayed pending the outcome of the FIR. The Appellant’s application for this stay is therefore granted.

28.

I do not consider it to be appropriate and in the interests of fairness and justice for this appeal to be stayed pending the final determination of the appeal proceedings in Marlborough. The Appellant’s application for this stay is therefore refused.

29.

I consider it to be appropriate to make the following directions.

DIRECTIONS

30.

IT IS DIRECTED THAT:

(1)

By no later than 10 January 2026, the Appellant shall submit to the Tribunal any application to amend their grounds of appeal which the Appellant intends to make.

(2)

Any amended grounds of appeal relied upon in an application made under Direction 1 must:

(a)

detail the reasons why they disagree with the Respondents’ decision that the amounts claimed were disallowed;

(b)

detail the legal and factual grounds relied upon in support of their appeal;

(c)

indicate why they believe the facts or legal reasoning relied upon by the Respondents are incorrect.

(3)

The Respondents are directed to provide a statement of case to the Appellant and Tribunal no later than 60 days after the latter of the expiry of the time allowed under Direction 1 or the determination/disposal of any application submitted by the Appellant under Direction 1.

(4)

Either party may apply at any time for these DIRECTIONS to be amended, suspended or set aside.

Right to apply for permission to appeal

31.

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: 10^thNOVEMBER 2025