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Farquharson v Revenue and Customs (Value Added Tax – DIY House Builders Scheme): FTTTx 28 Jun 2019

VALUE ADDED TAX – DIY House Builders Scheme – construction of a dwelling and a garage – claim of input VAT refund under s 35 VATA – occupation for over 8 years before sale – Certificate of Completion applied for in order to sell the home property – whether the claim time-barred – determination of … Continue reading Farquharson v Revenue and Customs (Value Added Tax – DIY House Builders Scheme): FTTTx 28 Jun 2019

Temple Finance Ltd and Another v Revenue and Customs: FTTTx 25 Jan 2016

VAT – whether supplies for a consideration below ‘open market value’ – whether ‘standard method override’ set out in Regulations 107A to F of the Value Added Tax Regulations 1995 should be applied – whether assessments ‘global assessments’ and whether made in time – appeal allowed in part Citations: [2016] UKFTT 41 (TC) Links: Bailii … Continue reading Temple Finance Ltd and Another v Revenue and Customs: FTTTx 25 Jan 2016

Garsington Opera Ltd v Revenue and Customs: FTTTx 28 Apr 2009

FTTTx Value Added Tax – Input tax – Attribution of input tax – Opera Company making both exempt and taxable supplies – Company makes exempt supplies of tickets and taxable supplies of sponsorship rights, programmes, CDs etc. to public and makes taxable supplies of productions to outside concert hall – Company pays input tax when … Continue reading Garsington Opera Ltd v Revenue and Customs: FTTTx 28 Apr 2009

Patel (T/A Cleggs Lane Service Station) v Revenue and Customs: FTTTx 2 Mar 2012

VAT – retail schemes – Regulations 67-75 Value Added Tax Regulations 1995 – appellant incorrectly used Apportionment Scheme 1 – appellant ineligible to use Apportionment Scheme 1 – assessment of output tax on basis of Apportionment Scheme 1 – appeal allowed in principle Citations: [2012] UKFTT 169 (TC) Links: Bailii Jurisdiction: England and Wales VAT … Continue reading Patel (T/A Cleggs Lane Service Station) v Revenue and Customs: FTTTx 2 Mar 2012

Conde Nast Publications Ltd v Customs and Excise: ChD 10 Jun 2005

Judges: Warren J Citations: [2005] EWHC 1167 (Ch), [2005] Eu LR 1014, [2005] BVC 478, [2005] BTC 5447, [2005] STC 1327, [2005] STI 1093 Links: Bailii Jurisdiction: England and Wales Citing: Appeal from – Conde Nast Publications Ltd v Customs and Excise VDT 7-Dec-2004 VDT Value added tax – input tax – time limits – … Continue reading Conde Nast Publications Ltd v Customs and Excise: ChD 10 Jun 2005

Total Network Sl v Customs and Excise Commissioners: CA 31 Jan 2007

The defendants suspected a carousel VAT fraud. The defendants appealed a finding that there was a viable cause of action alleging a ‘conspiracy where the unlawful means alleged is a common law offence of cheating the public revenue’. The defendants argued (inter alia) that the attempted recovery was void under the Billl of Rights. Held: … Continue reading Total Network Sl v Customs and Excise Commissioners: CA 31 Jan 2007

Conde Nast Publications Ltd v Revenue and Customs: CA 11 Jul 2006

Time limits for reclaim of VAT. The Court considered an argument that it should treat the Court of Appeal decision in Fleming (t/a Bodycraft) v Customs and Excise Commissioners [2006] STC 864 as inconsistent with EU law. Held: Chadwick LJ said: ‘I am content to assume that there may be circumstances in which the obligation … Continue reading Conde Nast Publications Ltd v Revenue and Customs: CA 11 Jul 2006

Ross Liddell Ltd v Revenue Customs: VDT 27 Apr 2006

Assessment: Appellant providing taxable and exempt supplies – recovery of input tax: assessment made on whole business without direct attribution – whether to best judgement – appeal allowed. VATA 1994 s.73, Value Added Tax Regulations 1995 101(2). Citations: [2006] UKVAT V19559 Links: Bailii Jurisdiction: England and Wales VAT Updated: 07 July 2022; Ref: scu.242767

London Institute (Now Known As the University of the Arts, London) v Revenue and Customs: VDT 6 Dec 2005

Value Added Tax – Claim for input tax under-declared – Claim made on 30 January 2001 for input tax under-claimed 1989-1996 – Legislation introducing limitation period for making claims had no provision for transitional relief – Effect on claim – Whether reasonable period sufficient for making claim – Value Added Tax Regulations 1995, SI 1995/2518, … Continue reading London Institute (Now Known As the University of the Arts, London) v Revenue and Customs: VDT 6 Dec 2005

Conde Nast Publications Ltd v Customs and Excise: VDT 7 Dec 2004

VDT Value added tax – input tax – time limits – whether appellant able to claim unclaimed input tax incurred more than three years previously despite regulation 29(1A) of the Value Added Tax Regulations 1995 Judges: Dr David Williams (Chairman) Citations: [2004] UKVAT V18869 Links: Bailii Statutes: Value Added Tax Regulations 1995 29(1A) Cited by: … Continue reading Conde Nast Publications Ltd v Customs and Excise: VDT 7 Dec 2004

University of Sussex v Commissioners of Customs and Excise: ChD 10 Oct 2001

The taxpayer had made a considered decision not to deduct certain input VAT claims against its payments made over a long period of time up to 1996. They later concluded that they should have made the deductions, and claimed them. The Commissioners asserted that the claims were now statute barred. Held: If the claim had … Continue reading University of Sussex v Commissioners of Customs and Excise: ChD 10 Oct 2001

Conde Nast Publications Ltd v Customs and Excise: CA 11 Jul 2006

The court was asked as to the time available to a taxpayer to make a claim for repayment of under-deducted input tax under regulation 29. Held: Though it might itself feel some discomfort at an earlier judgment interpreting a judgment of the European Court, the earlier decision was binding and must be followed. It would … Continue reading Conde Nast Publications Ltd v Customs and Excise: CA 11 Jul 2006

Rahman v Commissioners of Customs and Excise: CA 20 Dec 2002

The taxpayer appealed aganst rejection of his objection to an assessment to VAT Judges: Brooke, Chadwick, LJJ, Bodey J Citations: [2002] EWCA Civ 1881, [2003] STC 150 Links: Bailii Statutes: Value Added Tax Regulations 1995, Value Added Tax Act 1994 1 4 73(1) Jurisdiction: England and Wales Citing: Appeal from – Rahman T/A Khayam Restaurant … Continue reading Rahman v Commissioners of Customs and Excise: CA 20 Dec 2002

Royal and Sun Alliance Insurance Group plc v Her Majesty’s Commissioners of Customs and Excise: HL 22 May 2003

The landlord had elected to waive exemption to charging VAT on its lettings. The tenant relet the demised premises, but at first without charging VAT. It later charged VAT on the sublease, but the commissioners objected to the attempt of the claimants under regulation 109 to reclaim the VAT it had itself paid before that … Continue reading Royal and Sun Alliance Insurance Group plc v Her Majesty’s Commissioners of Customs and Excise: HL 22 May 2003

Fleming (T/A Bodycraft) v Revenue and Customs: HL 23 Jan 2008

The transitional rules introducing time limits for failing to deduct VAT inputs made insufficient allowance for the decisions in Marks and Spencer and Grundig. Held: Lord Hope said: ‘To be compatible with EU law, taxpayers were entitled to be told in advance of any transitional arrangements that would enable them to submit late accrued claims … Continue reading Fleming (T/A Bodycraft) v Revenue and Customs: HL 23 Jan 2008

Forth Wines Ltd (Formerly Dollar Trade Ltd) v Revenue and Customs: FTTTx 23 Jan 2012

Simplified Import VAT Accounting Scheme (SIVA); Excise Payment Security System Scheme (EPSS); Refusal to waive need to provide security to defer import VAT and excise duty; statutory discretion; whether refusal unreasonable having regard to HMRC published criteria; Value Added Tax Act 1994 s16(1)(4)and(8); Customs Excise and Management Act 1979 ss45 and127A, The Customs Duties (Deferred … Continue reading Forth Wines Ltd (Formerly Dollar Trade Ltd) v Revenue and Customs: FTTTx 23 Jan 2012

Rio Tinto London Ltd v Revenue and Customs: FTTTx 27 Nov 2014

FTTTx VALUE ADDED TAX- repayments – Appellant supplying investment management and administration services to a group pension fund – VAT charged on all services – no over-charge in respect of net of VAT costs themselves – Appellant ‘refunds’ part of payment made by pension fund – whether a decrease in consideration for the supply within … Continue reading Rio Tinto London Ltd v Revenue and Customs: FTTTx 27 Nov 2014

Nathaniel and Co Solicitors v Revenue and Customs: FTTTx 6 Oct 2010

Value Added Tax — repayment claim – s. 80 (1) Value Added Tax Act 1994 — three year time limit – s. 80 (4) Value Added Tax Act 1994 — whether valid claim for repayment of output tax was made pursuant to Regulation 37 Value Added Tax Regulations 1995/2518 — held no [2010] UKFTT 472 … Continue reading Nathaniel and Co Solicitors v Revenue and Customs: FTTTx 6 Oct 2010

London Cellular Communications Ltd v Revenue and Customs: FTTTx 8 Sep 2014

VAT — receipts from Apple stores for 1216 IPhones – receipts not valid invoices for purposes of regulation 14 of the value added tax regulations 1995 (as amended )- HMRC declined to exercise discretion under section 29 of the value added tax act 1954- 55% of receipts unnamed – legitimacy of the transactions in doubt … Continue reading London Cellular Communications Ltd v Revenue and Customs: FTTTx 8 Sep 2014

National Galleries of Scotland v Revenue and Customs: VDT 25 Nov 2005

Recovery of tax – claim involving output and input tax – claim purported to be made and partially met under s80 VATA – whether new or adjusted claim – date of claim – whether ‘capped’ under Reg 29(1A) – whether legislation imposing cap unlawful – what transitional period would be appropriate if 29(1A) can be … Continue reading National Galleries of Scotland v Revenue and Customs: VDT 25 Nov 2005

GSM Intertrade Ltd v Revenue and Customs: FTTTx 29 Apr 2014

FTTTx VALUE ADDED TAX – whether the mobile phones allegedly acquired by and then sold and despatched abroad by appellant had existed and whether they had corresponded to the goods described in the respective invoices – Regulation 14(1) Value Added Tax Regulations 1995 – whether reasonable for HMRC not to exercise discretion under Regulation 29 … Continue reading GSM Intertrade Ltd v Revenue and Customs: FTTTx 29 Apr 2014

The Roald Dahl Museum and Story Centre v Revenue and Customs: FTTTx 25 Mar 2014

FTTGc Value Added Tax – Input tax – Museum making both exempt and taxable supplies – Exempt supplies of admissions to museum and taxable supplies (standard rated and zero rated) of items sold in museum shop – Whether expenditure incurred in creating museum exhibits should be treated as residual input tax – Value Added Tax … Continue reading The Roald Dahl Museum and Story Centre v Revenue and Customs: FTTTx 25 Mar 2014

Holmes v Revenue and Customs: FTTTx 13 Mar 2014

FTTTx VAT – Penalties for late submission of EC Sales Lists – whether reasonable excuse – No – Appeal dismissed – Value Added Tax Act 1994, Sections 66, 70 and 71 – Value Added Tax Regulations 1995 Regulations 21 and 22. [2014] UKFTT 265 (TC) Bailii England and Wales VAT Updated: 03 December 2021; Ref: … Continue reading Holmes v Revenue and Customs: FTTTx 13 Mar 2014

Global Self Drive Ltd v Revenue and Customs: VDT 12 Jul 2005

VDT VALUE ADDED TAX – vehicle hire trader charging customers for insurance cover arranged by a policy taken out by the trader with a third-party insurer – whether the trader was making exempt supplies of insurance – Card Protection Plan v Customs and Excise Commrs. (Case C-349/96) [1999] STC 270 considered and applied – held … Continue reading Global Self Drive Ltd v Revenue and Customs: VDT 12 Jul 2005

University of Southampton v Customs and Excise: VDT 8 Mar 2005

VALUE ADDED TAX – input tax – whether goods or services supplied to the Appellant, and used for the purposes of publicly funded research, were used for the purpose of a business carried on by the Appellant – no – appeal dismissed – VATA 1994 Ss 24-26; VAT Regulations 1995 SI 1995 No. 2518 Reg … Continue reading University of Southampton v Customs and Excise: VDT 8 Mar 2005

Revenue and Customs v Iveco Ltd: UTTC 13 Jun 2016

UTTC VALUE ADDED TAX – whether section 80 VAT Act 1994 applies to claim to enforce directly effective right under article 11C(1) Sixth Directive to reduce taxable amounts to reflect rebates paid in periods before it was implemented in UK legislation – if so, whether claim made within time limit in section 80(4) – whether … Continue reading Revenue and Customs v Iveco Ltd: UTTC 13 Jun 2016

Martin-Jenkins v Revenue and Customs: FTTTx 13 May 2009

FTTTx Value added tax – whether goods fell to be zero-rated as goods intended for export to a place outside the member States supplied otherwise than to a taxable person to a person not resident in the United Kingdom – whether the Appellant was a person not resident in the United Kingdom at the time(s) … Continue reading Martin-Jenkins v Revenue and Customs: FTTTx 13 May 2009

Drosden Plantruck Ltd v Revenue and Customs: FTTTx 27 May 2009

FTTTx VALUE ADDED TAX – appeal against refusal of request by Appellant to retrospectively amend the effective date of voluntary registration – error by Appellant on application form for registration – schedule 1, para 9 VATA 1994, Regulation 111(2) VAT Regulations 1995 – appeal dismissed Citations: [2009] UKFTT 115 (TC) Links: Bailii Jurisdiction: England and … Continue reading Drosden Plantruck Ltd v Revenue and Customs: FTTTx 27 May 2009

Cable and Wireless Plc v Revenue and Customs: FTTTx 27 Mar 2009

FTTTx Value Added Tax – Whether the Appellant’s late claim for input tax, initially deducted in its Return, but later recovered by HMRC under an assessment, is a claim for input tax under Regulation 29 (1) of the 1995 VAT Regulations or a claim under section 80(1B) of the VAT Act 1994 for the recovery … Continue reading Cable and Wireless Plc v Revenue and Customs: FTTTx 27 Mar 2009

Prudential Assurance Company Ltd v Revenue and Customs: VDT 12 Feb 2009

VDT Value Added Tax – matter to be determined as preliminary issue – failure of taxable person to register – assessment for final return period of 34 months – whether illegal as contrary to Article 252 Principal VAT Directive – Commissioners’ powers to require return for period exceeding 12 months under Article 273 Principal VAT … Continue reading Prudential Assurance Company Ltd v Revenue and Customs: VDT 12 Feb 2009

Banbury Visionplus Ltd and others v Revenue and Customs: VDT 26 Oct 2005

VALUE ADDED TAX – partial exemption – opticians’ stores – special methods based on floor area agreed in 1997 and 1998 – special methods terminated by the Respondents in 2004 so that standard method applied – whether jurisdiction of the Tribunal is full or limited – limited – whether decision to terminate special methods was … Continue reading Banbury Visionplus Ltd and others v Revenue and Customs: VDT 26 Oct 2005

Community Housing Association Ltd v Revenue and Customs: VDT 10 Jun 2008

VDT Value added tax – input tax – Registered social landlord transfers its development project to a wholly-owned subsidiary – Whether able to reclaim input tax in respect of professional services commissioned before transfer – Regulation 109 VAT Regulations 1995 – Whether change of intention – No. Citations: [2008] UKVAT V20712 Links: Bailii Jurisdiction: England … Continue reading Community Housing Association Ltd v Revenue and Customs: VDT 10 Jun 2008

Mcinroy and Wood Ltd v Revenue and Customs: VDT 21 Aug 2008

VALUE ADDED TAX – Company providing investment management and advice – taxable and exempt supplies – deduction of residual input tax – whether Standard Method and/or proposed Special Method ‘fair and reasonable’ – VATA Section 26 – Regulations 101 and 102 of VAT Regulations 1995 – Appeal Refused. Citations: [2008] UKVAT V20780 Links: Bailii Jurisdiction: … Continue reading Mcinroy and Wood Ltd v Revenue and Customs: VDT 21 Aug 2008

Vision Express (UK) Ltd v Revenue and Customs: VDT 14 Nov 2008

VALUE ADDED TAX … partial exemption – retail opticians using floor-space based special method – override notice served – whether notice properly served – whether PESM achieved fair result – no – whether override notice sufficiently precise -VAT Regulations 1995, regs 99, 101, 102. 102A, 102B – override notice properly served and valid – appeal … Continue reading Vision Express (UK) Ltd v Revenue and Customs: VDT 14 Nov 2008

Lincoln Assurance Ltd v Revenue and Customs: VDT 17 Mar 2008

VDT VALUE ADDED TAX – input tax – Appellant made exempt supplies of finance (the sale of securities) outside the member states with a right of recovery of input tax (specified supplies) as well as taxable and exempt supplies – no goods or services supplied to the Appellant were used exclusively in making specified supplies … Continue reading Lincoln Assurance Ltd v Revenue and Customs: VDT 17 Mar 2008

National Provident Institution v Customs and Excise: VDT 18 Feb 2005

VDT VALUE ADDED TAX – input tax -Appellant made exempt supplies of finance (the sale of securities) outside the member states with a right to recovery of input tax (specified supplies) as well as taxable and exempt supplies – no goods or services supplied to the Appellant were used exclusively in making specified supplies – … Continue reading National Provident Institution v Customs and Excise: VDT 18 Feb 2005

Capital One Developments Ltd v Customs and Excise: VDT 9 Jun 2004

VDT VALUE ADDED TAX – avoidance – construction of premises for probable occupation by partially-exempt banking group – series of transactions designed wholly or partly to reduce liability for VAT – assumption that tribunal’s decision in Halifax plc correct – whether transactions artificial – whether tax avoidance sole purpose VALUE ADDED TAX – Sixth Directive … Continue reading Capital One Developments Ltd v Customs and Excise: VDT 9 Jun 2004

Regency Factors Plc v Revenue and Customs: UTTC 13 Nov 2020

VALUE ADDED TAX – bad debt relief – s 36 VATA 1994, reg 168 VAT Regulations 1995, Articles 73 and 90 Principal VAT Directive – factoring services – when is the consideration received – requirement in reg 168 for a ‘refunds for bad debts account’ Citations: [2020] UKUT 357 (TCC) Links: Bailii Jurisdiction: England and … Continue reading Regency Factors Plc v Revenue and Customs: UTTC 13 Nov 2020

Midlands Co-Operative Society Ltd v Revenue and Customs: VDT 20 Jul 2005

VALUE ADDED TAX – claim for repayment of overpaid output tax – VATA 1994 s 80, VAT Regulations 1995 reg 35 – industrial and provident societies – output tax paid by one society later transferring its engagements to another – whether right to claim refund transferred – Industrial and Provident Societies Act 1965, ss 16, … Continue reading Midlands Co-Operative Society Ltd v Revenue and Customs: VDT 20 Jul 2005

Oriental Delicacy Ltd v Revenue and Customs: VDT 20 Jun 2005

Value Added Tax – pre-registration expenditure on fitting-out restaurant premises – invoices in respect of ‘services’ pre-dating registration by more than 6 months – whether recoverable as ‘input tax’ following on registration – Regulation 111(2) (d) of VAT Regulations (SI 1995/2518) and Article 17 of the Sixth Directive – Appeal refused. Citations: [2005] UKVAT V19129 … Continue reading Oriental Delicacy Ltd v Revenue and Customs: VDT 20 Jun 2005

Capital One Bank (Europe) Plc v Revenue and Customs: VDT 9 Sep 2005

VALUE ADDED TAX – input tax – partially exempt trader – agreed special method for attribution of residual input tax – credit card bank – securitisation of credit card receivables – assignment of receivables to Jersey trustee – trustee holding assigned receivables on trust for Jersey company which issued loan notes on security of receivables … Continue reading Capital One Bank (Europe) Plc v Revenue and Customs: VDT 9 Sep 2005

Commissioners of Customs and Excise v Royal and Sun Alliance Insurance Group Plc: CA 9 Oct 2001

The respondent sought to deduct input tax from income it received from lettings. It had previously occupied the buildings itself making exempt supplies, but then let them. They later waved their exemption, and sought to deduct input tax for periods prior to the election. One issue was whether a lease was one supply or a … Continue reading Commissioners of Customs and Excise v Royal and Sun Alliance Insurance Group Plc: CA 9 Oct 2001

Royal and Sun Alliance Insurance Group plc v Commissioners of Customs and Excise: ChD 12 Oct 2000

Tenants of long lease where the landlord had elected to charge VAT, decided to seek sub-tenants. They delayed election themselves in order to assist such sub-tenants, but eventually waved their exemption and sought to reclaim the VAT paid to their own landlords. The commissioners objected. The deduction system was fundamental, and intended to relieve businesses … Continue reading Royal and Sun Alliance Insurance Group plc v Commissioners of Customs and Excise: ChD 12 Oct 2000

NHS Lothian Health Board v Revenue and Customs: FTTTx 14 Mar 2014

FTTTx Value Added Tax – Capital expenditure – recovery of residual input tax – VATA 1994, Ss 25 and 26 – Fleming rule/Section 121 FA 2008 – VAT Regulations 1995, nos. 101 and 102 – principles of quantification – onus and standard of proof – appeal refused Citations: [2014] UKFTT 258 (TC) Links: Bailii Jurisdiction: … Continue reading NHS Lothian Health Board v Revenue and Customs: FTTTx 14 Mar 2014

Revenue and Customs v Iveco Ltd: UTLC 13 Jun 2016

UTLC VALUE ADDED TAX – whether section 80 VAT Act 1994 applies to claim to enforce directly effective right under article 11C(1) Sixth Directive to reduce taxable amounts to reflect rebates paid in periods before it was implemented in UK legislation – if so, whether claim made within time limit in section 80(4) – whether … Continue reading Revenue and Customs v Iveco Ltd: UTLC 13 Jun 2016

Smith (T/A Heliops UK) v Revenue and Customs: FTTTx 19 Jan 2015

FTTTx VALUE ADDED TAX – supply – supplies made more than six months before registration – VAT Regulations 1995 reg 111 – whether supplies were of goods or services – argument that supplies were of an intangible asset – reference to HMRC Business Income Manual – held, under Article 14(1) of VAT Directive, that supplies … Continue reading Smith (T/A Heliops UK) v Revenue and Customs: FTTTx 19 Jan 2015

British Credit Trust Ltd v Revenue and Customs: FTTTx 1 Aug 2014

FTTTx VALUE ADDED TAX – hire-purchase agreements – whether input tax on repossession costs fully allowable – subsequent adjustment to appellant’s VAT account – whether a decrease in consideration leading to an adjustment for the purposes of regulation 38 VAT Regulations 1995 – whether an entitlement to bad debt relief under section 36 VATA 1994 … Continue reading British Credit Trust Ltd v Revenue and Customs: FTTTx 1 Aug 2014

Palatial Leisure Ltd v Revenue and Customs: FTTTx 22 Jul 2013

FTTTx VALUE ADDED TAX – partial exemption – whether attribution of input tax under regulation 101 of the VAT Regulations 1995 can take account of a taxable use of goods in a period more remote than the end of the prescribed accounting period in question which is brought about by a change in the law … Continue reading Palatial Leisure Ltd v Revenue and Customs: FTTTx 22 Jul 2013

Autologic Holdings Plc and others v Commissioners of Inland Revenue: HL 28 Jul 2005

Taxpayer companies challenged the way that the revenue restricted claims for group Corporation Tax relief for subsidiary companies in Europe. The issue was awaiting a decision of the European Court. The Revenue said that the claims now being made by other companies should proceed through the Commissioners who could implement European law directly. The taxpayers … Continue reading Autologic Holdings Plc and others v Commissioners of Inland Revenue: HL 28 Jul 2005

Revenue and Customs v Iveco Ltd; UTTC 13 Jun 2016

References: [2016] UKUT 263 (TCC) Links: Bailii Ratio: UTTC VALUE ADDED TAX – whether section 80 VAT Act 1994 applies to claim to enforce directly effective right under article 11C(1) Sixth Directive to reduce taxable amounts to reflect rebates paid in periods before it was implemented in UK legislation – if so, whether claim made … Continue reading Revenue and Customs v Iveco Ltd; UTTC 13 Jun 2016

Revenue and Customs v Patel; UTTC 7 Aug 2014

References: [2014] UKUT 361 (TCC) Links: Bailii UTTC VALUE ADDED TAX – Repayment claim under DIY Builders’ and Converters’ VAT Refund Scheme – claim refused by HMRC – appeal allowed by First-tier Tribunal – whether VATA s 35 and VAT Regulations 1995 reg 201 satisfied – whether permission pursuant to s 73A Town and Country … Continue reading Revenue and Customs v Patel; UTTC 7 Aug 2014

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