[2024] UKUT 00266 (TCC)

This was an oral hearing to consider the application of the Applicants (the “Application”) for permission to appeal against the decision of the First-tier Tribunal (Tax Chamber) (the “FTT”) released on 6 January 2023 (“the Decision”). The Applicants had requested that their application be dealt with at an oral hearing, to be held remotely, so this decision has not been preceded by any written decision of this Tribunal regarding permission to appeal.

The FTT refused permission to appeal in a decision dated 31 October 2023 (the “PTA Decision”).

The hearing was attended by Mr Andrew Thornhill KC as representative of the Applicants and Mr Adam Tolley KC as representative of HMRC. I had directed that HMRC had permission to make any written submissions in advance of the hearing. Mr Thornhill filed a skeleton argument and Mr Tolley filed written submissions in advance of the hearing. I heard oral submissions from both counsel.