The case, VP Evans (as executrix of HB Evans, deceased) & Ors v The Commissioners for HMRC [2025] UKFTT 1112 (TC), concerned 11 appeals challenging HMRC closure notices over capital gains tax.

The disputes relate to offshore trusts and the application of double taxation conventions between the UK and New Zealand, and the UK and Mauritius, covering tax years 1999/2000 to 2002/03.

Judge Christopher McNall granted the appellants’ disclosure application in part, directing HMRC to conduct further searches for tax returns and correspondence, with disclosure due by 30 October 2025. He refused requests for internal HMRC papers and confidential state-to-state communications.

In his decision, issued on 22 August 2025, Judge McNall stated: “I have used AI in the production of this decision… Principally, I have used AI to summarise the documents, but I have satisfied myself that the summaries — treated only as a first-draft — are accurate. I have not used the AI for legal research.”

He explained that the application was suitable for the approach as it was a paper-only case management matter.

“he parties’ respective positions on the issue which I must decide are contained entirely in their written submissions and the other materials placed before me,” he said.

“I have not heard any evidence; nor am I called upon to make any decision as to the honesty or credibility of any party.”

Judge McNall referred to recent guidance encouraging judicial use of digital tools.

The Senior President of Tribunals wrote in June 2024 that “full use should be made of any tools and techniques that are available to assist in the swift production of decisions”.

This position was endorsed earlier this year by the Upper Tribunal in Medpro Healthcare v HMRC [2025] UKUT 255 (TCC).

Emphasising his responsibility for the ruling, Judge McNall added: “This decision has my name at the end. I am the decision-maker, and I am responsible for this material.

“The judgment applied — in the sense of the evaluative faculty, weighing-up the arguments, and framing the terms of the order — has been entirely mine.”

This article was similarly written with the assistance of ChatGPT.