Frederiksen & Anor v Revenue and Customs (CASE MANAGEMENT - Application to Amend Statement of Case - Application for disclosure against applicant - Redaction - Restriction on use of disclosed documents by HMRC - Commissioners for Revenue and Customs Act 2005 s 17) [2025] UKFTT 854 (TC) (9 July 2025)

Frederiksen & Anor v Revenue and Customs (CASE MANAGEMENT - Application to Amend Statement of Case - Application for disclosure against applicant - Redaction - Restriction on use of disclosed documents by HMRC - Commissioners for Revenue and Customs Act 2005 s 17) [2025] UKFTT 854 (TC) (9 July 2025)

Disclosure of confidential documents is ordered; HMRC's use of disclosed documents cannot be restricted to the proceedings due to s.17 CRCA 2005; redaction of irrelevant/confidential information is permitted; Trustees are allowed to amend grounds of appeal as delay is justified and prejudice to HMRC is slight compared to injustice to Trustees.

Citation
[2025] UKFTT 854
Parties
First Appellant: Boris FrederiksEN as Trustee in Bankruptcy of Alpha Insurance A/S; Second Appellant: Boris Frederiksen as Trustee in Bankruptcy of Qudos Insurance A/S; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
09 July 2025
Procedural Posture
Tax Appeal / Case Management Order
Outcome
Disclosure application granted; collateral use restriction refused; redaction permitted; amendment application granted.
Legal Topics
Insurance Premium Tax, Disclosure, Redaction, Collateral Use, Amendment of Grounds of Appeal
Tax Law Insolvency Law Civil Procedure Insurance Premium Tax Disclosure Redaction Collateral Use Amendment of Grounds of Appeal

Case Brief

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Parties

Boris FrederiksEN as Trustee in Bankruptcy of Alpha Insurance A/S

First Appellant

Boris Frederiksen as Trustee in Bankruptcy of Qudos Insurance A/S

Second Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Tax Appeal / Case Management Order

Legal Issues

  1. 1 Whether disclosure of confidential documents by the Trustees should be ordered
  2. 2 Whether HMRC's use of disclosed documents should be restricted to the proceedings (collateral use)
  3. 3 Whether redaction of irrelevant/confidential information is permissible

Ratio Decidendi

Disclosure of confidential documents is ordered; HMRC's use of disclosed documents cannot be restricted to the proceedings due to s.17 CRCA 2005; redaction of irrelevant/confidential information is permitted; Trustees are allowed to amend grounds of appeal as delay is justified and prejudice to HMRC is slight compared to injustice to Trustees.

Court Disposition

Disclosure application granted; collateral use restriction refused; redaction permitted; amendment application granted.

Orders

  • Appellants to disclose redacted documents to Respondents
  • Redactions permitted for irrelevant/confidential information