UT/2024/000031 - [2025] UKUT 00254 (TCC)

For the reasons given above we refuse the Cross-Applications and strike out the appeal. We refuse the Privacy Application in so far as it seeks anonymity in relation to the application itself. We do however direct that this decision shall not be published or disseminated beyond the parties and their legal representatives until the appeal rights of Circleplane, Counsel and the Company (in so far as the latter might have appeal rights) have been fully exhausted. That is subject to the proviso that we will make copies of the decision available to the Judge and the President of the FTT Tax Chamber on the basis that it is to be treated as confidential unless and until it is published.