We recognise that clients demand specialist knowledge from barristers who are technically astute, excellent in court and aware of wider commercial issues and personable.
James Puzey, Head of St Philips Regulatory, has successfully led the HMRC Counsel team in the case of Bell and Mitchell v HMRC [2023] EWCA (Civ) 261.
The case concerned two individuals appealing assessments to tax penalties. One Appellant sought an order to prevent HMRC disclosing some of his tax records to the other Appellant. The Court of Appeal agreed with HMRC’s argument that the Tax Tribunal had no power to prevent the Commissioners disclosing the material pursuant to s.18 Commissioners of Revenue and Customs Act 2005 (‘CRCA 2005’).
The case provides important clarification on the disclosure rules in the Tribunal and the Commissioner’s powers and duties under the Rules and under the CRCA 2005. It emphasises that disclosure and admissibility in the Tribunal are two distinct concepts and should not be conflated.
Written by James Withers
St Philips Barristers are regulated by the Bar Standards Board.
55 Temple Row
Birmingham
B2 5LS
0121 246 7000
DX 723240 Birmingham 56
29 Park Square
Leeds
LS1 2PQ
© 2023 St Philips Chambers. All Rights Reserved.
Bespoke web design made in London by Yellowball.
We use cookies to give you the best possible experience. We can also use it to analyse the behaviour of users in order to continuously improve the website for you.
View our Data Policy for further information.
Cookie | Duration | Description |
---|---|---|
cookielawinfo-checkbox-analytics | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics". |
cookielawinfo-checkbox-functional | 11 months | The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional". |
cookielawinfo-checkbox-necessary | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary". |
cookielawinfo-checkbox-others | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other. |
cookielawinfo-checkbox-performance | 11 months | This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance". |
viewed_cookie_policy | 11 months | The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data. |