In Cider of Sweden Ltd v HMRC (Ernst & Young LLP
(Third Party)) [2022] UKFTT 76 (TC), the First-tier
Tribunal (“FTT”) has issued a significant, but narrow
decision regarding third-party access to pleadings filed in
proceedings before the FTT. (In this note,
“pleadings” refers to notices of appeal; grounds of
appeal; statements of case; and any further and better particulars
in respect of any such documents.)
Consistently with the approach of the Courts and Tribunals when
considering similar questions in the past, the FTT approached this
as an application of the principle of open justice. Previously, the
Tax Tribunals have held that open justice will usually permit third
parties to access: