Crooks v Revenue and Customs (PROCEDURE - application for a direction that HMRC provide further and better particulars and disclosure of documents in relation to discounted settlement opportunities for large companies involving Employee Benefit Trusts) [2025] UKFTT 1148 (TC) (30 September 2025)

Crooks v Revenue and Customs (PROCEDURE - application for a direction that HMRC provide further and better particulars and disclosure of documents in relation to discounted settlement opportunities for large companies involving Employee Benefit Trusts) [2025] UKFTT 1148 (TC) (30 September 2025)

The application was refused because the requested disclosure and particulars were not relevant or proportionate to the issues in dispute, the pleadings were incomplete, and the Tribunal lacks jurisdiction to direct disclosure regarding settlement terms offered to third parties. The application was premature and outside the Tribunal's statutory remit.

Citation
[2025] UKFTT 1148
Parties
Appellant: John Crooks; Respondents: The Commissioners for His Majesty's Revenue and Customs
Jurisdiction
United Kingdom
Judgment Date
30 September 2025
Procedural Posture
Application for Further and Better Particulars and Disclosure / Interlocutory Application Prior to Completion of Pleadings
Outcome
Application refused
Legal Topics
Disclosure, Employee Benefit Trusts, Settlement Offers, Jurisdiction of Tribunal, Procedural Fairness
Tax Law Civil Procedure Disclosure Employee Benefit Trusts Settlement Offers Jurisdiction of Tribunal Procedural Fairness

Case Brief

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Parties

John Crooks

Appellant

The Commissioners for His Majesty's Revenue and Customs

Respondents

Procedural Posture

Application for Further and Better Particulars and Disclosure / Interlocutory Application Prior to Completion of Pleadings

Legal Issues

  1. 1 Whether HMRC should be directed to provide further and better particulars and disclosure regarding discounted settlement opportunities for large companies involving Employee Benefit Trusts in 2015
  2. 2 Whether such disclosure is relevant and proportionate to the issues in dispute in the appeal
  3. 3 Whether the Tribunal has jurisdiction to direct disclosure relating to settlement terms offered to third parties

Ratio Decidendi

The application was refused because the requested disclosure and particulars were not relevant or proportionate to the issues in dispute, the pleadings were incomplete, and the Tribunal lacks jurisdiction to direct disclosure regarding settlement terms offered to third parties. The application was premature and outside the Tribunal's statutory remit.

Court Disposition

Application refused

Orders

  • The Appellant's application for a direction that HMRC provide further and better particulars and for disclosure of documents is refused.