His Majesty's Revenue and Customs v Ducas Ltd [2025] UKUT 00362 (TCC)
Upper Tribunal Tax and Chancery Decision of JUDGE THOMAS SCOTT and JUDGE JEANETTE ZAMAN on 23 October 2025
Read full decision:
DISCLOSURE – FTT ordered disclosure of adverse documents against HMRC but did not make an equivalent order against taxpayer – rolled-up hearing of oral renewal of application for PTA and substantive appeal - whether FTT made an error of law by not making an equivalent order against taxpayer – whether general principle that disclosure should be ordered on reciprocal basis – whether FTT’s decision was within the ambit of its case management discretion – held - permission to appeal granted on two grounds, but no general principle of reciprocity such that, on basis of application as made by HMRC, FTT’s decision was within generous ambit of its case management discretion - appeal dismissed