An application by a third party to the First-tier Tribunal for documents relating to an earlier appeal was granted on condition that a proportion of the transcriber costs be paid to the parties to the appeal. 

In November 2021, a third-party applicant (KPMG) applied to the First-tier Tribunal (FTT) for documents to be provided by the FTT in respect of proceedings between the appellants and HM Revenue and Customs (HMRC), pursuant to the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (SI 2009/273), Rules 2 and 5, and the inherent jurisdiction of the tribunal. The FTT’s decision in the appellants’ appeal was released in February 2022.

The application stated: “the applicant is currently instructed in another, unrelated, dispute with HMRC in which the same points of law have arisen: it is the applicant’s understanding that one of the points in issue in the appellants’ appeal is the question and extent of