“…Mitchell submitted that disclosure is determined by relevance, and relevance is to be assessed by reference to HMRC’s Statement of Case, relying on Burns v FCA [2018] 1 WLR 4161. HMRC’s case against both Mr Mitchell and Mr Bell depended on showing a “deliberate inaccuracy” (para 19 of Schedule 24 to the Finance Act 2007) which was tant…”
“…ples but are to be interpreted and applied in the same way as those rules or principles: Companies Act 2006 s.170(3) and (4), Burns v FCA [2017] EWCA Civ 2140, [2018] 1 WLR 4161, at [65]. As to the common law principles, see Item Software (UK) Ltd v Fassihi [2004] EWCA Civ 1244, [41]-[43], and British Midland Tool Ltd v Midland Interna…”