{"id":919123,"date":"2026-05-18T10:58:01","date_gmt":"2026-05-18T08:58:01","guid":{"rendered":"https:\/\/kohenavocats.com\/jurisprudences\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\/"},"modified":"2026-05-18T10:58:01","modified_gmt":"2026-05-18T08:58:01","slug":"smartprice-ne-ltd-v-the-commissioners-for-hmrc","status":"publish","type":"kji_decision","link":"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\/","title":{"rendered":"Smartprice (NE) Ltd v The Commissioners for HMRC"},"content":{"rendered":"
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Neutral Citation: [2026] UKFTT 00721 (TC) Case Number: TC 09885 FIRST-TIER TRIBUNAL TAX CHAMBER [Taylor House, London] Appeal reference: TC\/2014\/03403 PROCEDURE \u2013 Disclosure \u2013 Application for general and specific disclosure\u2013 Application refused Heard on: 24 February 2026 Judgment date:15 May 2026 Before TRIBUNAL JUDGE KIM SUKUL Between SMARTPRICE (NE) LTD Appellant and THE COMMISSIONERS FOR HIS MAJESTY\u2019S REVENUE AND CUSTOMS Respondents Representation: For the Appellant:Adam White of counsel, instructed by Brabners LLP For the Respondents: Howard Watkinson of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs DECISION Introduction 1. This is an application by the Appellant, Smartprice (NE) Limited, for a direction under rule 5(3)(d) of the First-tier Tribunal (Tax Chamber) Rules 2009 (\u201cthe Tribunal Rules\u201d) that the Respondents provide further disclosure. 2. The documents to which I was referred included the 489-page hearing bundle, authorities bundle (473 pages), supplemental bundles and documents, and skeleton arguments from both parties. 3. The application seeks, in summary, three categories of disclosure: (1) General disclosure in the form of a direction that the Respondents provide a list of all documents and information in their possession which: (a) may adversely affect their own case; or (b) may support the Appellant\u2019s case; (2) Specific disclosure of a number of documents said to be referred to in the Respondents\u2019 Statement of Case or witness evidence; and (3) Further specific disclosure of documents and classes of documents, including: (a) documents arising from criminal proceedings involving the Appellant\u2019s director and others; (b) internal HMRC communications and documents relating to the decisions under appeal; and (c) documents relating to other participants in the alleged transaction chains. 4. The application follows an earlier disclosure request made by the Appellant on 14 March 2025, and subsequent correspondence between the parties. The Respondents carried out searches and disclosed a number of documents but maintained that other requested documents could not be located, did not exist, or were not disclosable on grounds including relevance and proportionality. 5. The Appellant thereafter made this application on 1 August 2025 seeking directions for further disclosure. 6. The Respondents oppose the application. They object, in particular, to the request for general \u2018CPR-style\u2019 (a reference to the Civil Procedure Rules) disclosure, the disclosure of documents said not to exist or not capable of being located following reasonable searches and the disclosure of certain categories of documents, including those arising from criminal proceedings and internal HMRC material, on the grounds that such documents are not relevant to the issues in the appeal and that disclosure would be disproportionate. 7. In support of their position, the Respondents rely on the witness evidence of their officer, who explains the searches undertaken across HMRC systems and the reasons why certain documents were not identified or are no longer available in accordance with retention policies. He further indicates that material from the related criminal proceedings exists in substantial volume (approximately 60 boxes), the review of which would involve significant time and resources. 8. The Appellant\u2019s position is that further disclosure is required to enable it to fully advance its case and to ensure a fair determination of the appeal. The Respondents\u2019 position is that the application seeks disclosure going beyond what is required by the Tribunal Rules, is not necessary for the fair determination of the issues and is, in large part, either unsupported or disproportionate. background 9. The Appellant appeals against a number of VAT decisions made by the Respondents between 2014 and 2015, which resulted in the denial of input tax and consequential assessments in substantial amounts in respect of a series of transactions involving the purchase and sale of goods. 10. The Respondents\u2019 case, as set out in their Consolidated Statement of Case, is that the transactions on which the input tax claims were made were connected with the fraudulent evasion of VAT and that the Appellant knew, or should have known, of that connection, applying the well-established \u2018Kittel\u2019 principle (a reference to the decision of the Court of Justice of the European Union (the \u2018CJEU\u2019) in the joined cases Axel Kittel v Belgium; Belgium v Recolta Recycling SPRL (C-439\/04 and C-440\/04) [2006] ECR I-6161). 11. The Appellant disputes that the transactions were connected with fraud and denies that it had the requisite knowledge or constructive knowledge. The issues in the appeal therefore include whether there was a fraudulent tax loss, whether the Appellant\u2019s transactions were connected with such a loss, and whether the Appellant knew or ought to have known of that connection. 12. The appeal has a lengthy procedural history. Proceedings have been ongoing for a number of years and have involved the exchange of statements of case and witness evidence. The factual background to the appeal includes earlier criminal proceedings involving the Appellant\u2019s director and others arising out of the same or related business activities. Those proceedings were ultimately discontinued. The Appellant places reliance on the existence and conduct of those proceedings in support of its application for further disclosure, whereas the Respondents contend that the present appeal must be determined by reference to the pleaded issues before the Tribunal. 13. Against that backdrop, the Appellant made their disclosure request of 14 March 2025 seeking a wide range of documents, including material referred to in HMRC\u2019s case and documents arising from the criminal investigation. The Respondents responded on 9 May 2025, providing some material and maintaining objections to the remainder. 14. The present application, made on 1 August 2025, therefore arises from that dispute and I am required to determine whether, and to what extent, it is appropriate to direct further disclosure in order to deal with the case fairly and justly. Witness evidence 15. Witness evidence was provided on behalf of the Respondents by Mr Gavin Stock, a Higher Officer of HMRC with extensive experience in VAT and, in particular, the investigation of Missing Trader Intra-Community fraud and Kittel cases. 16. Mr Stock\u2019s evidence, which was not challenged, is directed to the searches undertaken in response to the Appellant\u2019s disclosure requests and the extent of the material held by HMRC. 17. Mr Stock explains that, following the Appellant\u2019s disclosure request of 14 March 2025, he carried out searches across HMRC systems using company names and VAT registration numbers. He provided to HMRC\u2019s legal team the documents that were located, and those documents were subsequently disclosed to the Appellant. 18. Mr Stock further explains that documents which could not be located were either not identified by those searches or were no longer available, having been deleted in accordance with HMRC\u2019s record retention policies. 19. Following the Appellant\u2019s application for further disclosure, Mr Stock undertook further searches in August and September 2025 using the same systems and methods. Additional documents were identified and disclosed, but a number of the requested items again could not be located. 20. In relation to material arising from the earlier criminal proceedings, Mr Stock states that HMRC holds a substantial quantity of archived material, amounting to approximately 60 boxes. He has not reviewed the contents of that material. His evidence is that reviewing such material would require significant time, resources, and cost, and that the question of whether such a review is proportionate is a matter for the Tribunal. 21. Mr Stock\u2019s evidence therefore goes to the nature and extent of the searches carried out by HMRC, the reasons why certain documents cannot be produced and the volume of material potentially falling within the categories of documents sought by the Appellant, particularly in relation to the criminal proceedings. 22. I accept Mr Stock\u2019s evidence. legal principles 23. Rule 5 of the Tribunal Rules provides that the Tribunal may regulate its own procedure and give directions in relation to the conduct or disposal of proceedings. In particular, rule 5(3)(d) provides that the Tribunal may direct a party to provide documents, information or submissions to another party. 24. Rule 27 sets out the default position as to disclosure. It requires a party to provide a list of documents of which it has possession, custody or control and on which it intends to rely. That rule establishes a deliberately limited disclosure regime in the Tribunal. Parties are not required, as a matter of course, to provide wider disclosure of documents which may be relevant but on which they do not rely, unless the Tribunal directs otherwise. 25. The power to depart from that default position must be exercised in accordance with the overriding objective in rule 2, which requires the Tribunal to deal with cases fairly and justly. This includes ensuring, so far as practicable, that parties are able to participate fully in proceedings, but also dealing with cases proportionately, having regard to their importance, complexity, and the resources of the parties, and avoiding unnecessary delay. 26. In determining whether to order further disclosure, I am guided by the principles set out by the Upper Tribunal in McCabe v HMRC [2020] UKUT 266 at [22] to [25] as follows: (1) Where the case concerns a high-value complex dispute, the starting proposition is that the parties should disclose relevant documents unless there is a good reason not to. (2) The Tribunal must exercise its discretion to order additional disclosure under rule 16 so as to give effect to the overriding objective under rule 2(3)(a) to deal with a case fairly and justly, which includes dealing with it in a way which is proportionate. (3) The approach of the Tribunal to disclosure is not determined by the Civil Procedure Rules. Rule 27 of the Tribunal Rules provides that a party produce a list of documents, which the other party may inspect, which that party intends to rely upon or produce in the proceedings, and applies to both standard and complex cases. Rule 16 gives the Tribunal power to order the production of any document in a person\u2019s possession or control which relates to an issue in the proceedings. (4) Relevance is to be assessed by reference to the issues in the case and the positions of the parties. Disclosure of documents is to ensure that the Tribunal has before it all the information which the parties reasonably require the Tribunal to consider in determining the appeal. 27. While in a complex, high-value case, the starting point is that relevant documents should be disclosed unless there is good reason not to do so, that is only a starting point. Relevance for these purposes is assessed by reference to the issues identified in the pleadings. However, it is not sufficient that documents are merely relevant. The Tribunal must also consider whether the material sought is required for the fair determination of the issues. 28. The judgment in HMRC v Citibank NA and E Buyer UK Limited [2017] EWCA Civ 1416 emphasised that there is an important distinction between an allegation that a taxpayer knew of a fraud and an allegation of dishonesty. In cases where only knowledge (including constructive knowledge) is alleged, as in a typical Kittel appeal, the Tribunal is not required to order disclosure equivalent to standard disclosure under the Civil Procedure Rules. Wider, CPR\u2011style disclosure may be appropriate where dishonesty is pleaded, but it does not arise automatically in cases concerned only with knowledge of fraud. 29. In HMRC v Smart Price Midlands Limited and Hare Wines Limited [2019] EWCA Civ 841 at [53], the Court of Appeal recognised that broader disclosure may in some instances be appropriate where HMRC holds extensive material of which the taxpayer is unaware, particularly in cases involving a wide-ranging assessment such as fitness and properness. However, that context differs from a Kittel appeal, where the issues are more narrowly defined by the transactions in dispute and the question of knowledge or connection to fraud. 30. The Tribunal must also be alert to the risk of ordering disclosure which amounts to a \u2018fishing expedition\u2019. Disclosure should not be ordered simply to allow a party to search for material which might assist its case. The request must be directed to material which is likely to be probative of an issue that the Tribunal must determine. 31. In considering the application, the Tribunal also must take into account whether the material sought is likely to exist, whether it is likely to be in the control of the other party, whether it has already been disclosed or is already in the Appellant\u2019s possession, and whether it is likely to be located through a further reasonable search. 32. Finally, proportionality is a central consideration. The Tribunal must weigh the likely probative value of the material sought against the burden, cost and delay involved in requiring its production, taking into account in particular the stage that the proceedings have reached. Discussion 33. The burden lies on the Appellant to demonstrate that it is appropriate to depart from the default position under rule 27 and to order the additional disclosure sought. As this is a high-value complex dispute, relevant documents should be disclosed unless there is good reason not to do so. However, relevance for these purposes is assessed by reference to the issues identified in the pleadings, with disclosure being the means to ensure that the Tribunal has before it all the information which the parties reasonably require the Tribunal to consider in determining the appeal. 34. I therefore begin from the position that this is a Kittel appeal in which the Respondents\u2019 case is that the Appellant knew, or ought to have known, that its transactions were connected with fraudulent evasion of VAT. There is no allegation of dishonesty pleaded and in accordance with the principles set out above, this is not a case in which CPR\u2011style disclosure arises as a matter of course. 35. The Appellant submits that the Tribunal should go beyond the more limited disclosure regime provided for by rule 27 on the basis of fairness, in particular by reference to the existence of earlier criminal proceedings and the possibility that the Respondents hold material of which the Appellant is unaware. I accept that, in an appropriate case, considerations of fairness may justify a departure from the default regime, including where there is a significant asymmetry of information. However, I am not satisfied that the Appellant has discharged the burden of establishing that the disclosure sought is required for the fair determination of the issues in this appeal. Much of the material sought is advanced on the basis that it may assist the Appellant or undermine the Respondents\u2019 case, and the application, in significant part, seeks disclosure in the hope that material favourable to the Appellant might be identified. 36. I therefore accept the Respondents\u2019 submissions that the scope of the application is overly broad and insufficiently tied to the issues arising on the pleadings. The relevance of documents for disclosure purposes must be assessed by reference to those issues. The Appellant\u2019s reliance on the wider background, including the earlier criminal proceedings and matters said to arise from them, does not, in my view, justify extending disclosure beyond what is required to determine the pleaded issues in this appeal. 37. For completeness, I deal expressly with the Appellant\u2019s reliance on the earlier criminal proceedings, including the fact that those proceedings were discontinued and the suggestion that there were deficiencies in disclosure in that context. I do not consider that those matters materially advance the Appellant\u2019s position. The issues before the Tribunal are those arising on the pleaded civil case. The fact that criminal proceedings were discontinued, or that issues arose in relation to disclosure in that separate context, does not, in my view, demonstrate that relevant material exists which ought to be disclosed in these proceedings. 38. The Appellant also relies on certain internal HMRC communications, including the document said to indicate a \u201cleap of faith\u201d in the Respondents\u2019 approach. I do not consider that such material establishes that further undisclosed documents are likely to exist which are probative of the issues in this appeal. At its highest, it forms part of the background to HMRC\u2019s investigation. It does not justify the wide-ranging disclosure sought, nor does it alter the requirement that disclosure be tied to the pleaded issues. 39. Further, I do not accept that the asserted similarity between the allegations in the criminal proceedings and the present appeal assists the Appellant. The nature and scope of the allegations in the criminal proceedings were different. In any event, this appeal must be determined by reference to the Respondents\u2019 pleaded case. It does not follow that material said to be relevant in the criminal context will be relevant, or reasonably required, for the determination of the issues here. 40. In addition, I have considered that these proceedings have been ongoing for a considerable period of time. To introduce a materially expanded disclosure exercise at this stage carries a real risk of further delay and inefficiency in the progress of the appeal. The overriding objective requires the Tribunal to deal with cases fairly and justly, which includes avoiding unnecessary delay and ensuring proportionality in the use of resources. 41. So far as specific categories of documents are concerned, I accept the evidence of Mr Stock in relation to the searches undertaken. That evidence explains the systems searched, the methodology employed and the reasons why certain documents could not be located, including that they do not exist or are no longer available. In the absence of any cogent evidence to the contrary, I am not satisfied that further searches are likely to yield material relevant to the issues in the appeal and I am not minded to order further searches in those circumstances. 42. I have also considered the Appellant\u2019s reliance on the earlier Tribunal directions concerning disclosure of documents and the subsequent indication that certain paper records could not be located. While that gives rise to understandable concern, I do not consider that it undermines the adequacy of the searches carried out for the purposes of this application. On the evidence before me, I am satisfied that reasonable searches have now been undertaken and that this issue does not justify further disclosure. 43. To the extent that any of the documents sought are already in the possession of the Appellant as a party to the criminal proceedings, it would not be appropriate to order their disclosure. Disclosure is not required where the requesting party already has access to the material. I have also considered the Appellant\u2019s argument that fairness requires wider disclosure because the Respondents may hold material of which the Appellant is unaware. While I accept that there may be material within HMRC\u2019s possession which has not been seen by the Appellant, there is no sufficient evidential basis for concluding that such material is likely to be probative of the issues in dispute. The volume of material potentially falling within the categories sought, particularly in relation to the criminal proceedings, is substantial. Requiring its review and disclosure would involve a significant exercise, with attendant cost and delay. 44. Taking all matters into account, and having regard to the legal principles set out above, I have concluded that the default disclosure regime under rule 27 remains appropriate. This is a pure Kittel case, in which no dishonesty is pleaded, the issues are defined by the transactions in dispute and the question of knowledge. I am not satisfied that the Appellant has demonstrated that the disclosure sought is appropriate, proportionate, or required to give effect to the overriding objective. On the contrary, I consider that granting the application would risk a disproportionate burden, delay and inefficiency, which are inconsistent with the fair determination of the appeal. 45. For those reasons, I refuse the application. Right to apply for permission to appeal 46. This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to \u201cGuidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)\u201d which accompanies and forms part of this decision notice. KIM SUKUL TRIBUNAL JUDGE Release date: 15 May 2026<\/p>\n<\/div>\n

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Sources officielles :<\/strong> consulter la page source<\/a><\/p>\n

Open Justice Licence v2.0 (The National Archives). Republication avec attribution. Computational analysis necessite accord complementaire.<\/em><\/p>\n<\/div>\n","protected":false},"excerpt":{"rendered":"

Neutral Citation: [2026] UKFTT 00721 (TC) Case Number: TC 09885 FIRST-TIER TRIBUNAL TAX CHAMBER [Taylor House, London] Appeal reference: TC\/2014\/03403 PROCEDURE \u2013 Disclosure \u2013 Application for general and specific disclosure\u2013 Application refused Heard on: 24 February 2026 Judgment date:15 May 2026 Before TRIBUNAL JUDGE KIM SUKUL Between SMARTPRICE (NE) LTD Appellant and THE COMMISSIONERS FOR HIS MAJESTY\u2019S REVENUE AND CUSTOMS…<\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_crdt_document":""},"kji_country":[7608],"kji_court":[7915],"kji_chamber":[],"kji_year":[7610],"kji_subject":[7612],"kji_keyword":[7633,7662,9671,8397,7636],"kji_language":[7611],"class_list":["post-919123","kji_decision","type-kji_decision","status-publish","hentry","kji_country-royaume-uni","kji_court-first-tier-tribunal-tax-chamber","kji_year-7610","kji_subject-fiscal","kji_keyword-appellant","kji_keyword-disclosure","kji_keyword-documents","kji_keyword-material","kji_keyword-tribunal","kji_language-anglais"],"yoast_head":"\nSmartprice (NE) Ltd v The Commissioners for HMRC - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\/\" \/>\n<meta property=\"og:locale\" content=\"zh_CN\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Smartprice (NE) Ltd v The Commissioners for HMRC\" \/>\n<meta property=\"og:description\" content=\"Neutral Citation: [2026] UKFTT 00721 (TC) Case Number: TC 09885 FIRST-TIER TRIBUNAL TAX CHAMBER [Taylor House, London] Appeal reference: TC\/2014\/03403 PROCEDURE \u2013 Disclosure \u2013 Application for general and specific disclosure\u2013 Application refused Heard on: 24 February 2026 Judgment date:15 May 2026 Before TRIBUNAL JUDGE KIM SUKUL Between SMARTPRICE (NE) LTD Appellant and THE COMMISSIONERS FOR HIS MAJESTY\u2019S REVENUE AND CUSTOMS...\" \/>\n<meta property=\"og:url\" content=\"https:\/\/kohenavocats.com\/zh-hans\/jurisprudences\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\/\" \/>\n<meta property=\"og:site_name\" content=\"Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"\u9884\u8ba1\u9605\u8bfb\u65f6\u95f4\" \/>\n\t<meta name=\"twitter:data1\" content=\"17 \u5206\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\\\/\\\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\\\/\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\\\/\",\"name\":\"Smartprice (NE) Ltd v The Commissioners for HMRC - Ma\u00eetre Hassan Kohen, avocat en droit p\u00e9nal \u00e0 Paris\",\"isPartOf\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\"},\"datePublished\":\"2026-05-18T08:58:01+00:00\",\"breadcrumb\":{\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\\\/#breadcrumb\"},\"inLanguage\":\"zh-Hans\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\\\/\"]}]},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/smartprice-ne-ltd-v-the-commissioners-for-hmrc\\\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"Jurisprudences\",\"item\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/jurisprudences\\\/\"},{\"@type\":\"ListItem\",\"position\":3,\"name\":\"Smartprice (NE) Ltd v The Commissioners for HMRC\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/#website\",\"url\":\"https:\\\/\\\/kohenavocats.com\\\/zh-hans\\\/\",\"name\":\"Kohen Avocats\",\"description\":\"Ma\u00eetre Hassan Kohen, avocat p\u00e9naliste \u00e0 Paris, intervient exclusivement en droit p\u00e9nal pour la d\u00e9fense des particuliers, notamment en mati\u00e8re d\u2019accusations de viol. 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