UT (Tax & Chancery) UT/2023/000050 - [2025] UKUT 00123 (TCC)

For reasons set out in my decision dated 19 April 2024 (the “April Decision”), I allowed the Applicant (“Mr Reynolds”) to apply for permission to further amend his Amended Reference.

The April Decision sets out the procedural history of Mr Reynolds’ reference, the reasons why I allowed Mr Reynolds to apply for permission to further amend his Amended Reference and the terms on which I did so.

Because I was unsure of what amendments Mr Reynolds would be seeking to make, I made it clear, in the April Decision at [43], that any application Mr Reynolds might make “must set out succinctly, but comprehensively and very clearly, so that there can be absolutely no doubt at all about [Mr Reynolds’] position, precisely why he says that the Authority are wrong to conclude in the Decision Notice that he lacks integrity. He should also indicate what evidence he would lead to support his factual allegations.”

On 17 May 2024 Mr Reynolds applied for permission to further amend his Amended Reference. On 13 June 2024 the Authority made submissions in reply to Mr Reynolds’ application and Mr Reynolds briefly replied to those submissions on 19 June 2024. I also have Mr Reynolds’ submissions dated 7 February 2024 and the Authority’s submissions in response. These were submitted after a directions hearing on 26 January 2024 and were the materials I considered in reaching my April Decision.

On 19 July 2024 I released a decision (the “July Decision”) setting out the extent to which I proposed to allow Mr Reynolds to further amend his Amended Reference and invited the parties’ final comments. I received comments from Mr Reynolds on 26 July and from the Authority on 2 August. This decision is essentially my July Decision, revised in the light of those comments.