TC09676 - [2025] UKFTT 01278 (TC)

For the reasons set out above, the appeal is dismissed except to the extent necessary to reduce the assessments/adjustments to the agreed figure of £8,432,896.86.

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.