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 by the Trustees is ordered, with redaction of irrelevant information permitted. No restriction is imposed on HMRC's collateral use of disclosed documents due to s 17 CRCA 2005, which overrides common law implied undertakings. Amendment of grounds of appeal is allowed as timely and fair, outweighing any prejudice to HMRC.

Citation
[2025] UKFTT 854 (TC)
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 Ruling
Outcome
Applications granted in part
Legal Topics
Insurance Premium Tax, Disclosure, Redaction, Collateral Use of Documents, Amendment of Grounds of Appeal
Tax Law Insolvency Law Civil Procedure Insurance Premium Tax Disclosure Redaction Collateral Use of Documents 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 Ruling

Legal Issues

  1. 1 Whether disclosure of confidential documents by appellants can be restricted in use by HMRC
  2. 2 Whether redaction of irrelevant/confidential information is permissible
  3. 3 Whether amendment of grounds of appeal should be allowed

Ratio Decidendi

Disclosure of confidential documents by the Trustees is ordered, with redaction of irrelevant information permitted. No restriction is imposed on HMRC's collateral use of disclosed documents due to s 17 CRCA 2005, which overrides common law implied undertakings. Amendment of grounds of appeal is allowed as timely and fair, outweighing any prejudice to HMRC.

Court Disposition

Applications granted in part

Orders

  • Disclosure of confidential documents by Trustees to HMRC ordered
  • Redaction of irrelevant/confidential information permitted