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

There is no contemporaneous documentary evidence of the design or operation of the Trading Strategies that are now relied upon by the Traders as being their explanations for placing the Large Orders (and the other large orders during the Relevant Period).

We have summarised above the notes of the meetings with Compliance and HR (and revert to those in the Evaluation). The descriptions in this section of the decision of the evidence given by the Traders are not findings by the Tribunal that these strategies were being pursued by the Traders.

Mr Urra’s evidence was that he was pursuing what we have referred to as an Information Discovery Strategy. Mr Sheth’s evidence was that he was also pursuing this strategy, which he said had been shown to him by Mr Urra and which he had been given permission to try. In closing submissions, Mr George and Mr Bailin both referred to these strategies as being “similar” to each other. Mr Lopez’s evidence was that he was pursuing the Anticipatory Hedging Strategy.