If matters are not resolved at an earlier stage, the case will progress to the First-tier Tribunal. The procedures at, and in the lead-up to, any such hearing are a consequence of the legal question as to which party has the burden of proof.

8.3.1 Burden of proof – generally

It is generally well understood that taxpayers have the burden of proof at appeals. However, this is somewhat an over-simplification as the burden can differ in relation to different aspects of an appeal.

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