Background
VP Evans (as executrix of HB Evans, deceased) & Others v The Commissioners for HMRC concerned a challenge to HMRC’s closure notices on capital gains tax arising from offshore trusts and the operation of double taxation treaties with New Zealand and Mauritius. The tribunal resolved the matter by granting disclosure in part, requiring HMRC to provide additional specified documents while rejecting broader requests for internal materials and diplomatic correspondence (the appellants’ application thus succeeded only in part).
AI interaction
“I have used AI in the production of this decision.” The tribunal explained that AI tools were used solely to generate first-draft summaries of documents, not for legal research or evaluative reasoning, and that final judgment was entirely the court’s own. This marks the first published UK tribunal decision openly disclosing AI use in judgment drafting, setting an important precedent for transparency in judicial practice while highlighting both the potential utility and the limits of AI in the courtroom.