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

Mr Kalaris’s evidence was that when he said there was “no connection”, he did not mean there was “no linkage at all” between the ASA and the capital raising, but instead that there was “no legal connection”. He said he did not think it necessary to tell Mr Beauchamp there was a factual connection, because this had already been disclosed in the Prospectus, and because he had already said, in response to Q1 that Barclays was going down “two paths” with the Qataris, being a strategic partnership and an investment relationship, and so had understood the factual connection was already clear.