UT (Tax & Chancery) UT-2022-0000150 - [2024] UKUT 00254 (TCC)

Mr Kalaris lacked candour when he told Ms Yazdani that he did not have the impression that there were “some sort of notes or any sort of physical document in existence”. His responses to questions about the briefing, the meeting on 5 April, and the events during the weekend of 15-16 December lack credibility.

On the basis of those findings, we find as a fact that Mr Kalaris knew the GenVen Report existed before the meeting on 17 December 2012. His statement to the contrary during the 2014 Interview was thus untrue; Mr Kalaris knew it was untrue, and he thus acted dishonestly.