UT/2024/000069 - [2025] UKUT 00236 (TCC)

The FTT accepted HMRC’s case that “the MUC scheme as a whole was and is fraudulent”. The Lead Appellants’ case is that this finding was not open to the FTT in circumstances where HMRC’s pleaded case did not identify who the perpetrators of the fraud were or the acts they did which constituted the fraud and how such acts or relevant knowledge were to be attributed to the Lead Appellants. The FTT declined to make any finding on the identity of the perpetrators of the fraud on the basis that the issue had not been sufficiently pleaded.