UT/2023/000055 - [2025] UKUT 00028 (TCC)

Ms Brown does not disagree with the UT’s approach of interpreting the words “party to” in their statutory and factual context but argues that for a number of reasons that the UT’s analysis on that context was wrong. Her overall submission, made by reference to the wider statutory context and the explanatory notes for the Finance Bill which brought in the relevant ITA 2007 provisions, together with the ordinary meaning of the words “party to”, is that the words should be construed narrowly. HMRC’s case, as submitted by Miss Hughes, is simply that Coconut UT is directly on point, correct and should be followed and applied to dismiss the appeal.