Kammac Limited v The Commissioners for HMRC
Decision date: 13 March 2026
Neutral citation: [2026] UKFTT 397 (TC)
Overall AI summary confidence: high
Short overview
This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.
AI confidence in this short overview: high
Kammac, an authorised warehouse keeper, sought specific disclosure from HMRC in appeals against three excise duty assessments and a linked penalty; HMRC had already made extensive standard and voluntary disclosure. The Tribunal refused the appellant’s application for four outstanding categories of specific disclosure because the requests were overbroad, unfocussed, lacked time and goods-specific limits, and would be disproportionately burdensome given the disclosed material. The Tribunal confirmed the application as framed did not meet the necessity, relevance and proportionality requirements for specific disclosure.
Ratio decidendi
This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.
AI confidence in this ratio decidendi summary: high
An applicant for specific disclosure must show the material is necessary for a fair disposal, likely exists and is in the other party’s control, has not already been disclosed, would be found by a reasonable search, and that ordering disclosure would be proportionate; vague, overbroad or not time-limited requests (for example seeking material merely “associated with” other accounts or third parties) may be refused as disproportionate.
Obiter dicta
This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.
AI confidence in this obiter dicta summary: high
The Tribunal indicated it is unlikely to order internal HMRC communications or material about other accounts unless a direct, demonstrated relevance to the assessed goods or specific issues is shown, and that the Tribunal will not itself reformulate or narrow an applicant’s broadly drafted disclosure requests for them.