Taxes Consolidation Act 1997 section 949AQ

Case stated for High Court

Section 949AQ sets out the required contents of a case stated, the manner in which it is to be drafted and completed by the Appeal Commissioners, the timelines governing each stage of the process, and the obligations on the parties in relation to exhibits and onward transmission to the High Court.

• A case stated must contain the commissioners' findings of fact, an outline of the parties' arguments and case law, the determination and reasons, and the point of law on which the High Court's opinion is sought.
• The Appeal Commissioners are solely responsible for drafting the case stated and must not delegate that task to either party.
• Strict timelines apply at each stage: 3 months for the draft, 42 days for representations, 21 days for completion and signing, and 14 days for the requesting party to send the case stated to the High Court.
• The requesting party must compile copies of all exhibits specified in the case stated and include them when sending it to the High Court.