[2025] UKUT 00185 (TCC)
Upper Tribunal Tax and Chancery Chamber

[2025] UKUT 00185 (TCC)

Fecha: 09-Abr-2025

Internal work in support

Internal work in support

157.

Around the same time, work began within the Bank to support the Deloitte review; this was a joint project involving the risk team, the finance team and the commercial lending team.

158.

On the basis of Ms Gillan’s evidence, we find that the issue which was being addressed was whether the loans had been correctly classified for regulatory reporting purposes; the teams were not checking the quantum of the loans; the identity of the borrowers, or the security on which the loans had been made. She described the work as follows:

“[They] were tasked with reviewing individual loans to, firstly, understand which classification had been applied, but then applying the decision tree to ensure that the correct classification had, in fact -- so they were comparing what was on the system versus having applied the decision tree, what
classification should have been applied.”

159.

In order to carry out that exercise, the teams therefore applied the KPMG decision trees, and, as we have already found, one of the factors in those decision trees was whether the SME supporting factor applied, see §94.