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Introduction
Introduction
This is the application of the Appellant dated 29 April 2025 that these proceedings are stayed pending
the outcome of the Further Independent Review of the Loan Charge (‘FIR’); and
final determination of the appeal proceedings, in Marlborough DP Ltd v HMRC [2025] EWCA Civ 796 (‘Marlborough’).
The application is opposed by the Respondents (‘HMRC’).
The hearing lasted 1 day. The documents to which I was referred were contained within the 381-page document bundle, 98-page supplementary bundle and skeleton arguments from both parties.