Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
As a successful party in litigation content with the outcome of a decision you would not expect to have to give immediate consideration to appealing it. However following the Court of Appeal’s decision in HMRC v SSE Generation Ltd [2021] EWCA Civ 105 (SSE) successful parties in the First-tier Tribunal (FTT) have found themselves in precisely this unusual position. With SSE stirring up difficulties for taxpayers and HMRC alike and generating litigation in the Upper Tribunal (UT) as to whether parties need permission to raise certain arguments it is unsurprising that the UT has given further consideration to the issue and that the Tribunal Procedure Committee has now weighed in.
Recap and the way forward
In SSE the Court of Appeal determined that a respondent to...
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Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
As a successful party in litigation content with the outcome of a decision you would not expect to have to give immediate consideration to appealing it. However following the Court of Appeal’s decision in HMRC v SSE Generation Ltd [2021] EWCA Civ 105 (SSE) successful parties in the First-tier Tribunal (FTT) have found themselves in precisely this unusual position. With SSE stirring up difficulties for taxpayers and HMRC alike and generating litigation in the Upper Tribunal (UT) as to whether parties need permission to raise certain arguments it is unsurprising that the UT has given further consideration to the issue and that the Tribunal Procedure Committee has now weighed in.
Recap and the way forward
In SSE the Court of Appeal determined that a respondent to...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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