Upper Tribunal Tax and Chancery Chamber [2025] UKUT 00367 (TCC) Fecha: 09-Ene-2025 Discussion, Analysis and Decision Discussion, Analysis and Decision8.I refuse permission to appeal in respect of the Applicant’s grounds of appeal as they hold no realistic prospects of success and do not raise any arguably material errors of law in the FTT’s Decision. Heading JUDGE RUPERT JONES Introduction UT’s jurisdiction in relation to appeals from the FTT Grounds of Appeal Discussion, Analysis and Decision The FTT Decision Ground a. misinterpretation of paragraph 8 Grounds b. and c. – purposive interpretation Conclusion on grounds Conclusions