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CHECKLISTS
When preparing for a remote (virtual) hearing in arbitration proceedings there are many logistical and practical considerations to be taken into account, planned and, often, budgeted for. This Checklist should help ensure the key aspects of a remote hearing have been considered in advance so the process runs as smoothly as possible. This Checklist refers to both fully-remote hearings (when all participants are appearing remotely) and hybrid hearings (when some of the participants are present at the same location while the others are appearing remotely). Where relevant, specific considerations in relation to those two forms of hearing are set out in this Checklist. While they can bear different meanings and some practitioners have preferences for one or the other, the terms remote and virtual are used interchangeably for the purposes of this Checklist. This Checklist contemplates the requirements of merits, rather than procedural, remote hearings, although some of the points made will be relevant to both hearing types. This Checklist assumes that there are no legal or procedural bars to conducting a merits
PRACTICE NOTES
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or the judiciary. This Practice Note outlines what to do after a taxpayer has decided to appeal an HMRC decision to the First-tier Tax Tribunal (FTT). It covers the period from the beginning of the appeal process to the date of the hearing, and discusses: • the appeal form—where to find it and tips for completing it • the allocation of the case by the FTT to a category and the consequences of that allocation • pre-hearing directions issued by the FTT • when the proceedings may be stayed • dealing with evidence which is expected to be given by video or telephone from a location outside the UK • when expert evidence may be directed • preparing: ◦ witness statements ◦ trial bundles ◦ skeleton arguments, and • the use of artificial intelligence (AI) in tax litigation For the next stage, see Practice Note:
PRECEDENTS
General Date of meeting [Insert date] Chair/lead [Insert name and role] Deadline date of RFP/ITT [Insert date] Prospective client [Insert name] Persons in attendance [Insert names and roles] Agenda What is expected of the team at the presentation? [What does the RFP/ITT say?][What have you learned since starting this tender process?] People and environment:—who will be in the audience?—what do we know about
PRACTICE NOTES
This Practice Note provides guidance on the interpretation and application of the relevant provisions of the CPR. Depending on the court in which your matter is proceeding, you may also need to be mindful of additional provisions—see further in the section Court specific guidance below. Preparing for application hearings in the digital age Traditionally, application hearings involved in-person attendance in a physical courtroom and the use of hard-copy documents. However, particularly since the start of the coronavirus (COVID-19) pandemic, there has been a significant shift towards more technology-based methods of disposing of applications. Remote hearings are currently the default position for shorter application hearings in a number of courts. For detailed guidance on remote hearings, see Practice Note: Remote and hybrid hearings in civil proceedings. In addition, documents for use at court are increasingly being submitted electronically, particularly in the High Court. For detailed guidance, see Practice Notes: • When and where is CE-File applicable?—from 1 October 2025 • How to use CE-File—from 1 October 2025 • Electronic bundles in civil proceedings • Electronic communication and
PRACTICE NOTES
NOTE: On 1 October 2026, a newly formed Business and Property Division replaces the Chancery Division—see News Analysis: The new Business and Property Division of the High Court. This Practice Note contains references to, and information derived from, the Chancery Guide. It is understood that a Business and Property Division Guide is being drafted and it is assumed this will replace the Chancery Guide. Existing links to the Chancery Guide will remain in content until a replacement is released. NOTE: with effect from 1 January 2026, the Financial List in the Chancery Division is operating a pilot under CPR PD 51ZH whereby certain documents used in public hearings (including witness statements and skeleton arguments) will be made available to the public by default. Practitioners making applications in this list should familiarise themselves with the pilot and make sure appropriate steps are taken to protect their clients when preparing affected documents. For guidance, see Practice Note: Non-party access to court documents and information in civil proceedings. Applications in the Chancery Division If
PRACTICE NOTES
NOTE: with effect from 1 January 2026, the Commercial Court and London Commercial Court are operating a pilot under CPR PD 51ZH whereby certain documents used in public hearings (including witness statements and skeleton arguments) will be made available to the public by default. Practitioners making applications in these courts should familiarise themselves with the pilot and make sure appropriate steps are taken to protect their clients when preparing affected documents. For guidance, see Practice Note: Non-party access to court documents and information in civil proceedings. Applications in the Commercial Courts If your matter is proceeding in the Commercial Court, the provisions of the Commercial Court Guide will apply to any application you make. If you are proceeding in one of the Circuit Commercial Courts then the Commercial Court Guide will apply as modified by the Circuit Commercial Court Guide (Circuit Commercial Court Guide, para A1.3). This Practice Note provides guidance on applications in the Commercial Court and the Circuit Commercial Courts (referred to collectively in this Practice Note as ‘the Commercial
PRACTICE NOTES
Applications in the King’s Bench Division If your matter is proceeding in the King’s Bench Division (KBD) the provisions of the King’s Bench Guide will apply to any application you make. This Practice Note provides guidance on applications in the KBD with reference to the relevant provisions of the King’s Bench Guide. This Practice Note is focused on how to prepare for an application hearing in the KBD, looking in particular at the documentation that needs to be prepared in advance of the hearing and how and when it should be provided to the court. For guidance on other aspects of applications procedure in the KBD, see the following Practice Notes: • Making an application in the King’s Bench Division (KBD) • Determination of applications in the King’s Bench Division (KBD) The following general points should be noted: • the King’s Bench Guide provides practical information about proceedings in the KBD but it is not a substitute for the CPR and must be read alongside those rules (King’s Bench Guide,
PRACTICE NOTES
Applications in the Technology and Construction Court If your matter is proceeding in the Technology and Construction Court (TCC) the provisions of the TCC Guide will apply to any application you make. This Practice Note provides guidance on applications in the TCC with reference to the relevant provisions of the TCC Guide. This Practice Note is focused on how to prepare for an on-notice application hearing in the TCC, looking in particular at the documentation that needs to be prepared in advance of the hearing and how and when it should be provided to the court. For guidance on the process of making an application in the TCC, from pre-application considerations up to issue of the application, see Practice Note: Making an application in the Technology and Construction Court (TCC). The following general points should be noted: • the TCC Guide provides practical information about proceedings in the TCC but it is not a substitute for the CPR and must be read alongside those rules (TCC Guide, paras 1.1.1–1.1.3).
PRACTICE NOTES
STOP PRESS: This Practice Note is being updated to take account of the introduction of a 24–week statutory framework for appeals lodged on or after 12 August 2026 by appellants receiving asylum accommodation support, and non-detained appellants who are liable to deportation under section 3(5)(a) of the Immigration Act 1971 (IA 1971). See: LNB News 14/08/2026 4 and reg 2 of the Border Security, Asylum and Immigration Act 2025 (Commencement No 5) Regulations 2026, SI 2026/766. The new framework is being underpinned by a new Practice Direction. Note also that the Government’s Immigration and Asylum Bill 2026 would establish a new Independent Immigration Appeals Authority to replace the First-tier Tribunal (Immigration and Asylum Chamber). See News Analysis: A guide to the Immigration and Asylum Bill 2026. The procedural steps to be followed in a First-tier Tribunal appeal are examined in the Practice Note on Procedure in the First-tier Tribunal (IAC). This Practice Note looks at the practical issues involved in the preparation of the evidence, appellant’s
PRACTICE NOTES
This Practice Note provides some general guidance for practitioners that may be new to advocacy in international arbitration, including some practical tips both for an advocate’s preparation and for conducting advocacy at a hearing. While the importance of written advocacy cannot be understated, this Practice Note focuses primarily on oral advocacy. The use of advocacy in arbitration Oral advocacy forms an integral part of many international arbitration proceedings. Counsel may encounter advocacy throughout the life of an arbitration, including at: • case management conferences and procedural hearings (the first of which, in particular, often involves contentious procedural issues about how the arbitration should be conducted) • preliminary issue hearings (eg contesting jurisdiction, or resolving discrete points of law) • interim applications (eg applications relating to document production, applications relating to redaction of privileged documents, seeking further and better particulars, or seeking security for costs), and • merits hearings, which incorporates a broad range of advocacy such as opening statements, submissions to the tribunal on particular issues, direct and re-examination
PRACTICE NOTES
This Practice Note is part of the Lexis+® UK Corporate Private equity buyout transaction collection. At completion, the requisite formalities to complete and implement the private equity buyout transaction are undertaken, including the execution of the stock transfer form and delivery and execution of all completion deliverables as set out in the share purchase agreement (SPA) and the investment agreement (IA). Exchange (the signing of the SPA and the IA) and completion may occur simultaneously or may be split, depending on whether the agreements for the transaction are unconditional or conditional, respectively. In addition, exchange and completion may occur in face-to-face meetings or virtually (via telephone and email). See Practice Note: Issues arising where there is split exchange and completion—share and asset purchases. Preparations for the completion meeting Prepare list of documents/completion agenda A list of documents, setting out the documents that need producing and detailing who has responsibility for producing each document, should be prepared well in advance of completion. The list should set out a timetable for when
PRACTICE NOTES
This Practice Note is part of the Share purchase transaction collection. At completion, the requisite formalities to complete and implement the transaction are undertaken, including the execution of the stock transfer form and delivery and execution of all completion deliverables as set out in the share purchase agreement (SPA). Exchange (the signing of the SPA) and completion may occur simultaneously or may be split, depending on whether the agreement for the transaction is unconditional or conditional, respectively. In addition, exchange and completion may occur in face-to-face meetings or virtually (via telephone, email or other electronic means). See Practice Note: Issues arising where there is split exchange and completion—share and asset purchases. Preparations for the completion meeting Prepare list of documents/completion agenda A list of documents, setting out the documents that need producing and detailing who has responsibility for producing each document, should be prepared well in advance of completion. The list should set out a timetable for when such documents need to be produced. It allows the parties to keep