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

The Authority accepted that Mr Kalaris had not seen a copy of the GenVen Report before the meeting on 17 December 2012, when he was shown it by Mr Jenkins and Mr Harding. However, the Authority’s position was that Mr Kalaris knew that the GenVen Report existed before that meeting, and that he had therefore given false and/or misleading evidence during the 2014 Interview, and that he knew that evidence was untrue and/or misleading at the time he gave it.

Saranac’s position was that Mr Kalaris had given honest evidence to the Authority in the course of the 2014 Interview, because he did not know the GenVen Report existed until he was shown a copy during the meeting on 17 December 2012, because Mr Tinney had decided to conceal the existence of the Report from him and from Barclays more generally.