UT (Tax & Chancery) UT/2025/000047 - [2025] UKUT 00362 (TCC)

Rule 2(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (the “FTT Rules”) sets out that the overriding objective of the FTT Rules is to enable the FTT to deal with cases fairly and justly, and Rule 2(3) provides that the FTT must seek to give effect to the overriding objective when it exercises any power under the FTT Rules.

In relation to disclosure, Rule 27 provides:

“27(1) This rule applies to Standard and Complex cases.

(2)

Subject to any direction to the contrary, within 42 days after the date the respondent sent the statement of case (or, where there is more than one respondent, the date of the final statement of case) each party must send or deliver to the Tribunal and to each other party a list of documents -

(a)

of which the party providing the list has possession, the right to possession, or the right to take copies; and

(b)

which the party providing the list intends to rely upon or produce in the proceedings.

(3)

A party which has provided a list of documents under paragraph (2) must allow each other party to inspect or take copies of the documents on the list (except any documents which are privileged).”