UT (Tax & Chancery) UT-2022-000134 UT-2022-000135 UT-2022-000137 - [2025] UKUT 00214 (TCC)

The Instance lasts ten seconds and the trading activity is as follows:

Mr Sheth’s evidence was that he could not identify anything which would have prompted a sell-side Large Order. He did identify an RFQ from Banca Popolare at 16.54 for a €2.5m buy-side order on a bond (which had been priced by Mr Lopez but traded away). If that had been the prompt, Mr Sheth said he should then have placed a large order to buy 500 lots to pursue the Information Discovery Strategy, and suggested that the placing of an order to sell may have been an error on his part and would explain why he took the decision to cancel the Large Order so quickly.

In cross-examination, Mr Shivji challenged Mr Sheth’s evidence that he did not discuss with Mr Lopez (who had priced the RFQ) his decision to place a Large Order against the direction of that client flow. Mr Shivji also challenged Mr Sheth’s decision to deploy the Information Discovery Strategy where the RFQ had traded away. In terms of the trading activity, the Authority relied on the Small Order of five lots having been live for eight seconds without filling, the Large Order was placed, the Small Order traded and the Large Order was cancelled 1.382 seconds after the Small Order filled.