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

UT (Tax & Chancery) Case Number: UT/2025/000047

DISCLOSURE – FTT ordered disclosure of adverse documents against HMRC but did not make an equivalent order against taxpayer – rolled-up hearing of oral renewal of application for PTA and substantive appeal - whether FTT made an error of law by not making an equivalent order against taxpayer – whether general principle that disclosure should be ordered on reciprocal basis – whether FTT’s decision was within the ambit of its case management discretion – held - permission to appeal granted on two grounds, but no general principle of reciprocity such that, on basis of application as made by HMRC, FTT’s decision was within generous ambit of its case management discretion - appeal dismissed

Hearing venue: The Rolls Building

London

EC4A 1NL

Judgment date: 23 October 2025

Before

JUDGE THOMAS SCOTT

JUDGE JEANETTE ZAMAN

Between

THE COMMISSIONERS FOR HIS MAJESTY’S

REVENUE AND CUSTOMS

Applicants/Appellants

and

DUCAS LTD

Respondent

Representation:

For the Applicants/Appellants: Adam Tolley KC, Howard Watkinson and Laura Inglis,

instructed by the General Counsel and Solicitor for His Majesty’s Revenue and Customs

For the Respondents: Christoper Stone KC and David Bedenham KC, instructed by Joseph Hage Aaronson & Bremen LLP

DECISION