Upper Tribunal Tax and Chancery Chamber

UT (Tax & Chancery) UT-2023-000064 - [2024] UKUT 00394 (TCC)

Fecha: 19-Nov-2024

Mr Staley’s position

Mr Staley’s position

70.

Many of the amendments to the Statement of Case are agreed. However, there are a number of amendments to which Mr Staley objects. These are divided into 7 different categories in Mr Staley’s skeleton filed for the purposes of this hearing. It is convenient to adopt those categories for the purpose of determining which of those amendments which are objected to should be permitted.

71.

Mr Staley’s stated basis for objecting to those categories essentially boil down to two arguments as follows:

(1)

Some amendments are objected to on the basis that they raise matters falling outside the Tribunal’s jurisdiction because they are not capable of forming part of the subject matter of the reference.

(2)

Otherwise, Mr Staley relies on the Tribunal’s inherent discretion to disallow amendments and raises various arguments as to why the Tribunal should exercise that discretion in this case.