Commentary

A3.713 First-tier Tax Chamber rules

Administration and compliance

A3.713 First-tier Tax Chamber rules

A3.713 First-tier Tax Chamber rules

Generic features

The following is a summary of the important generic rules, ie those that apply to all chambers of the First-tier Tribunal. For details of the significant features specific to the Tax Chamber, see below.

  1.  

    •     the overriding objective of the rules is to enable the Tribunal to deal with cases fairly and justly. Parties to an appeal must co-operate with the Tribunal both to this end and generally, although no specific obligations are applied1

  2.  

    •     the Tribunal must bring to the attention of the parties, where appropriate, the availability of any appropriate alternative procedure for resolution of disputes. This requirement is common across the rules, though its practicable application to tax may be limited in the context of the development of HMRC internal review procedures (see A5.710, A5.711) and HMRC's statutory obligation to recover the tax owed2

  3.  

    •     the key feature of the generic rules, in many ways, is that of the Tribunal's broad case management powers. These replace often quite prescriptive rules around practice and

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