Mitchell v Revenue and Customs Comrs

Subject Matter

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 — Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (SI 2009/273), rr 5, 15

[2023] EWCA Civ 261; [2023] Ch 251; [2023] 2 WLR 1201; [2023] STC 603; [2023] WLR(D) 118; The Times, 24 April 2023, CA

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