UT/2024/000066 - [2025] UKUT 00065 (TCC)

Neither sets of disclosure sought are required in order to resolve the matters before the tribunal fairly and justly. Contrary to the claimant’s submission, for similar reasons concerning the lack of assistance the documents sought would provide to resolution of the issues, I disagree that HMRC have failed in their duty of candour in not providing such documents. Given my conclusion that disclosure is not necessary I do not deal with the further points raised by the parties regarding the breadth of request of disclosure sought and the time and costs issues for HMRC if they were ordered to comply with it.

The claimant’s application for disclosure is dismissed.