UT (Tax & Chancery) UT/000097/2023 - [2025] UKUT 00034 (TCC)

For the reasons given above I propose to direct the hearing of a preliminary issue. It will be necessary for that direction to clearly specify the nature and scope of the preliminary issue. The parties should seek to agree the terms of the preliminary issue and associated directions for hearing within 14 days of the release of this direction.