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Contentious tax quarterly: Summer 2024

The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).

The overarching theme of this quarterly review is the principle of open justice. On two sides of the same coin we consider: (1) recent developments relevant to taxpayers who wish to retain their anonymity when appealing matters to the tax tribunals; and (2) two cases dealing with applications by non-parties to the First-tier Tribunal (FTT) to obtain information relating to other taxpayers’ appeals. We also discuss a recent decision of the FTT that relates to the provisions in TCGA 1992 ss 103KA–103KH (and the transitional provision at F(No. 2)A 2015 s 43(2)) dealing with the taxation of carried interest as it appears likely that the direction of travel is for such challenges to become more common.

Open justice 1: anonymity and privacy

The starting point in both civil and...

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