UT (Tax & Chancery) UT/ xx /20 xx - [2025] UKUT 00255 (TCC)

Remedy if this appeal is allowed

At the outset of the hearing, we indicated that if we were to allow the appeal, we would not be minded to remake the Decision, but would remit it to the FTT. The Appellants and HMRC would – in an ideal world – have wanted to save time and expense by having us remake the Decision (a sentiment we share). However, it was recognised that remaking the Decision would not be straightforward. Both parties agreed with this approach. In the event, the day and a half allocated for the appeal was fully utilised in submissions on the four grounds of appeal and there would have been no time to hear detailed submissions on how we should remake the appeal.

We are grateful to both parties for the quality of their submissions and the care with which they were presented.

THE DECISION