The Law Reports (Chancery Division)
[2023] Ch 251
Court of Appeal
Mitchell and another v Revenue and Customs Commissioners
[2023] EWCA Civ 261
2023 Jan 25; March 10
Arnold, Carr, Whipple LJJ
Revenue— Confidentiality— Disclosure— Taxpayers’ appeals to First-tier Tribunal heard together— Revenue wishing to grant first taxpayer’s request for disclosure of otherwise confidential documents relating to tax affairs of second taxpayer— Whether revenue empowered to make disclosure sought— Whether tribunal’s direction required— Whether tribunal having jurisdiction to adjudicate exercise by revenue of powers to make such disclosure— Whether tribunal empowered to direct revenue to make such disclosure—
Commissioners for Revenue and Customs Act 2005 (c 11), s 18
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Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (SI 2009/273), rr 5, 15