14 September 2023
You’re barred: failure to disclose in the FTT
In a Tax Journal article, Sophie Rhind and Victoria Braid comment on the strict approach taken by the FTT to HMRC’s failure to comply with an order requiring the disclosure of documents in the case of Ebuyer v HMRC.
In Ebuyer v HMRC, the FTT barred HMRC from participating in proceedings as a result of HMRC’s failure to comply with an unless order requiring the disclosure of documents. The taxpayers’ ability to apply for specific directions for disclosure is an important strategic step in the context of the relatively limited disclosure obligations in the FTT. Taxpayers will be reassured by the strict approach taken by the FTT when HMRC fails to comply with directions for specific disclosure. Ultimately, the decisions serve as a reminder of the importance of respecting disclosure obligations.
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