UT (Tax & Chancery) UT/2023/000103 - [2025] UKUT 00102 (TCC)

The FTT made numerous findings of fact; these are scattered through the text of the FTT Decision. We decided it was helpful to bring those findings together, along with other facts which formed part of the background and which were not in dispute, in order that the Grounds, the parties’ submissions and our decision could be more easily understood.

There are further findings of fact later in our decision, these include in particular findings which are under challenge by MLT in these proceedings.