Citations:
[2002] EWHC Admin 283
Links:
VAT
Updated: 29 May 2022; Ref: scu.140097
Richards J
[1999] EWHC Admin 825
England and Wales
Updated: 28 May 2022; Ref: scu.140089
The society had an unpaid governing board (like a board of directors) and certain senior employees who were called directors but who were not on the board (though they attended meetings). Exemption from VAT was refused on the ground that the society was not managed and administered on an essentially voluntary basis because these people were paid.
[1999] EWHC Admin 677
Reference from – Kennemer Golf and Country Club v Staatssecretaris van Financien, Zoological Society of London v Commissioners of Customs and Excise Case ECJ 21-Mar-2002
The bodies sought exemption from certain elements of VAT as ‘non-profit’ making or ‘voluntary’ bodies. Their activities included trading activities, but they did not set out to make a profit overall.
Held: For certain exemptions, the term . .
Lists of cited by and citing cases may be incomplete.
Updated: 28 May 2022; Ref: scu.139941
ECJ Taxation – VAT – Directive 77/388/EEC- Article 13B(d)(6) – Exemption of the management of special investment funds – Directive 85/611- Undertakings for collective investment in transferable securities (UCITS) – Investment fund management companies – Definition of ‘management’ – Application of the exemption to third-party managers – A ‘specific’ business which ‘viewed broadly’ forms a ‘distinct whole’ – Levying of tax on unlawful commercial activities – Principle of fiscal neutrality
C-275/11, [2012] EUECJ C-275/11, [2013] EUECJ C-275/11
Directive 77/388/EEC 13B(d)(6)
European
Updated: 28 May 2022; Ref: scu.465992
Where a sum was paid to a party and an un-ascertained part expected to be paid to a third party (for post and carriage), that part was not subject to VAT in the recipient’s hands but in the carrier’s hands when charged by him.
Times 25-Nov-1998, [1998] EWHC Admin 1048
Updated: 27 May 2022; Ref: scu.139169
A licence fee paid to a shopkeeper for the installation of a cigarette vending machine in the shop and to maintain and operate it was a licence to occupy land and so was an exempt supply.
Times 29-Jul-1998, Gazette 09-Sep-1998, [1998] EWHC Admin 727, [1998] STC 841
Appeal from – Commissioners of Customs and Excise v Sinclair Collis Limited CA 23-Jun-1999
The commissioners appealed against a decision that the agreements under which the respondents hired out vending displays to shops were for the occupation of land, and so were exempt from VAT.
Held: (a) the terms of the Directive are to be . .
Lists of cited by and citing cases may be incomplete.
Updated: 27 May 2022; Ref: scu.138848
The court heard an appeal by the Commissioners from the VAT Duties Tribunal that ‘Spreadable butter’ and ‘Ammix butter’ from New Zealand made and imported by the respondent are ‘manufactured directly from milk or cream’, and are not ‘recombined butter’, and are therefore subject to a lower rate of tariff duty under Annex I to Council Regulation 1600/95 (as amended).
Dyson J
[1999] V and DR 425, [1998] EWHC Admin 674
England and Wales
See also – Commissioners of Customs and Excise v Anchor Foods Ltd (No 2) ChD 24-Mar-1999
The claimant intended to seek recovery of a very substantial sum from the defendant. On learning of the defendant’s intention to sell its assets, it sought an order freezing them.
Held: The court has the discretion to order a freezing of a . .
See also – Commissioners of Customs and Excise v Anchor Foods Ltd (No 3) ChD 8-Jul-1999
The Civil Procedure Rules have not changed the common law rules which say that an interlocutory order for costs could not be varied by another judge sitting at first instance, except only in exceptional circumstances where it appeared for example . .
See also – Customs and Excise v Anchor Foods Ltd (No.4) ChD 18-Oct-1999
. .
See Also – Commissioners of Customs and Excise v Broomco (1984) Ltd (Formerly Anchor Foods Ltd) CA 17-Aug-2000
When an appeal is lodged in a VAT dispute, the discretion as to whether to require the appellant to lodge security for costs in the appeal, was a decision exclusively to be decided by the tribunal itself. A decision as to such security could not be . .
Lists of cited by and citing cases may be incomplete.
Updated: 27 May 2022; Ref: scu.138795
[1998] EWHC Admin 679
England and Wales
Appealed to – Mirror Group plc v Commissioners of Customs and Excise, Cantor Fitzgerald International v Same ECJ 9-Oct-2001
A potential lessee who did not have an interest in immovable property agreed to take a lease in return for money paid by the landlord. The transaction was not exempt from value-added tax under article 13(B)(b) as ‘the leasing or letting of immovable . .
Appeal from – Mirror Group plc v Commissioners of Customs and Excise, Cantor Fitzgerald International v Same ECJ 9-Oct-2001
A potential lessee who did not have an interest in immovable property agreed to take a lease in return for money paid by the landlord. The transaction was not exempt from value-added tax under article 13(B)(b) as ‘the leasing or letting of immovable . .
Lists of cited by and citing cases may be incomplete.
Updated: 27 May 2022; Ref: scu.138800
[1998] EWHC Admin 597
Appealed to – Commissioners of Customs and Excise v Pilgrims Language Courses Limited CA 23-Jul-1999
A language school which sought to teach English was correct to include as part of that exempt supply, the cost of accommodation and catering. Transport to and from the airport and photographs necessary for the course were also exempt, being closely . .
Appeal from – Commissioners of Customs and Excise v Pilgrims Language Courses Limited CA 23-Jul-1999
A language school which sought to teach English was correct to include as part of that exempt supply, the cost of accommodation and catering. Transport to and from the airport and photographs necessary for the course were also exempt, being closely . .
Lists of cited by and citing cases may be incomplete.
Updated: 27 May 2022; Ref: scu.138718
[1998] EWHC Admin 477
England and Wales
Updated: 27 May 2022; Ref: scu.138598
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 for the deduction of input tax despite the introduction of the time limit. They were entitled to be given sufficient notice to familiarise themselves with the new regime, including the period of grace that was to be allowed for the submission of accrued claims during a transitional period.’
Lord Hope of Craighead, Lord Scott of Foscote, Lord Walker of Gestingthorpe, Lord Carswell, Lord Neuberger of Abbotsbury
[2008] UKHL 2, [2008] 1 All ER 1061, [2008] BVC 221, [2008] Eu LR 455, [2008] STI 181, [2008] NPC 5, [2008] 1 WLR 195, [2008] BTC 5096, [2008] 1 CMLR 48, [2008] STC 324
Value Added Tax Act 1994, Value Added Tax Regulations 1995 (SI 1995/2518).
England and Wales
Cited – Marks and Spencer plc v Commissioners of Customs and Excise ECJ 11-Jul-2002
The claimant challenged the reduction of the limitation period from six years to three for the reclaiming of overpaid VAT with immediate effect, depriving it of the opportunity to recover sums paid in excess. The company sold vouchers. It paid VAT . .
Cited – Grundig Italiana SpA v Minstero delle Finanze ECJ 24-Sep-2002
Europa Internal taxes contrary to Community law – Recovery of sums paid but not due – National legislation retroactively reducing time-limits for bringing proceedings – Compatibility with the principle of . .
At VDT – Fleming (T/A Bodycraft) v Customs and Excise VDT 23-Apr-2004
VDT INPUT TAX – whether claim made in 2000 for input tax for 1989 and 1990 for which no tax invoice was issued was part of a claim made in 1993 – no – whether the 2000 claim was prevented by the 3 year cap . .
At ChD – Fleming T/A Bodycraft v Commisioners of Customs and Excise ChD 25-Feb-2005
Appeal against dismissal of the Appellant’s appeal from the decision of the Commissioners of Customs and Excise to refuse to repay to the Appellant input tax on three new Aston Martin motor cars out of a batch of thirteen such cars purchased by the . .
Cited – Revenue and Customs v The Investment Trust Companies SC 11-Apr-2017
Certain investment trust companies (ITCs) sought refunds of VAT paid on the supply of investment management services. EU law however clarified that they were not due. Refunds were restricted by the Commissioners both as to the amounts and limitation . .
Cited – Littlewoods Ltd and Others v Commissioners for Her Majesty’s Revenue and Customs SC 1-Nov-2017
The appellants had overpaid under a mistake of law very substantial sums in VAT over several years. The excess had been repaid, but with simple interest and not compound interest, which the now claimed (together with other taxpayers amounting to 17 . .
Cited – Revenue and Customs v Taylor Clark Leisure Plc SC 11-Jul-2018
Several companies within a group paid VAT. Later the basis of charge to output VAT was revised, and a reclaim became due, but the VAT group had been dissolved. Could the appellant, former lead within the group now make the reclaim.
Held: . .
Cited – Prudential Assurance Company Ltd v Revenue and Customs SC 25-Jul-2018
PAC sought to recover excess advance corporation tax paid under a UK system contrary to EU law. It was now agreed that some was repayable but now the quantum. Five issues separated the parties.
Issue I: does EU law require the tax credit to be . .
Cited – FMX Food Merchants Import Export Co Ltd v Revenue and Customs SC 29-Jan-2020
This appeal concerns the meaning and effect of the phrase ‘Customs Debt’ in article 221(4) of the former Customs Code of the EU, contained in Council Regulation (EEC) No 2913/92. Customs duties may be due under ‘post-clearance demands’ and the Court . .
Lists of cited by and citing cases may be incomplete.
Updated: 27 May 2022; Ref: scu.263817
VAT – assessment under s73 VATA – standard rated sales incorrectly recorded as zero rated – output tax under-declared – whether assessment made to best judgment – yes – whether assessment displaced by appellant – no – appeal dismissed
[2020] UKFTT 468 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.656870
Vat – Supply : Single or Multiple – VALUE ADDED TAX – Conveyancing – Appellant firm of solicitors obtaining online property searches from an external search agency – Agency invoiced appellant for the cost of obtaining access to documents without the addition of VAT – Appellant treated this as a disbursement and invoiced its clients for the same amount without VAT – Whether a disbursement? – No – Whether VAT should have been applied by the Appellant? – Yes – Appeal dismissed
[2017] UKFTT 666 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.595444
Import duty underpaid for Customs error is recoverable unless the mistake was undiscoverable by the trader acting in good faith.
Times 29-Jul-1997, Gazette 16-Jul-1997, [1997] EWHC Admin 614
Council Regulation 2913/92 (OJ 1992 L302/1)
Updated: 26 May 2022; Ref: scu.137559
VAT – Whether transfer of a business can be a transfer as a going concern and/or total transfer of business assets if transferee is a member of a VAT group which makes supplies only to another member of the same VAT group – Appeal dismissed
[2013] UKFTT 741 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.519627
FTTTx VAT – preliminary issue – whether claim in respect of article 11C(1), Sixth Directive precluded by time limit in s 80(4) VATA or otherwise – assumed bonus payments made in period 1 January 1978 to 31 December 1989 giving rise to reductions in taxable amounts – VAT regulations 1995, reg 38 – jurisdiction of tribunal – s 83(1) VATA – whether claim otherwise barred under EU law by failure to make claim in reasonable time
[2013] UKFTT 763 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.519628
FTTTx VAT – preliminary issue – whether claim in respect of article 11C(1), Sixth Directive precluded by time limit in s 80(4) VATA or otherwise – assumed bonus payments made in period 1 January 1978 to 31 December 1989 giving rise to reductions in taxable amounts – VAT regulations 1995, reg 38 – jurisdiction of tribunal – s 83(1) VATA – whether claim otherwise barred under EU law by failure to make claim in reasonable time
[2013] UKFTT 751 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.519629
FTTTx VAT – zero rating of leaflets – Group 3 Sch 8 VATA – appeal against assessment- s83(1)(p)- whether tribunal has jurisdiction to consider fairness of decision to assess Technip considered.
[2013] UKFTT 739 (TC)
England and Wales
Updated: 26 May 2022; Ref: scu.519626
Lightman J
[1997] EWHC Admin 231
Updated: 25 May 2022; Ref: scu.137176
[1997] EWHC Admin 105
England and Wales
Appealed to – Commissioners of Customs and Excise v British Telecommunications Plc CA 18-Mar-1998
The delivery of a quantity of cars is a separate supply from the purchases of the cars themselves and the VAT on the delivery charges is reclaimable as an input. . .
Appeal from – Commissioners of Customs and Excise v British Telecommunications Plc CA 18-Mar-1998
The delivery of a quantity of cars is a separate supply from the purchases of the cars themselves and the VAT on the delivery charges is reclaimable as an input. . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 May 2022; Ref: scu.137050
[1997] EWHC Admin 67
Appealed to – Commissioners of Customs and Excise v Civil Service Motoring Association CA 10-Dec-1997
The exemption from VAT for the making of credit arrangements extends to the surrounding activities; not just the making of arrangement. . .
Appeal from – Commissioners of Customs and Excise v Civil Service Motoring Association CA 10-Dec-1997
The exemption from VAT for the making of credit arrangements extends to the surrounding activities; not just the making of arrangement. . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 May 2022; Ref: scu.137012
[1997] EWHC Admin 5
Appealed to – Regina v Commissioners of Customs and Excise ex parte Littlewoods Home Shopping Group Limited CA 17-Feb-1998
Charge to VAT on basis already withdrawn on suppliers to self financed retailer after cessation of trading was contrary to EC law . .
Appeal from – Regina v Commissioners of Customs and Excise ex parte Littlewoods Home Shopping Group Limited CA 17-Feb-1998
Charge to VAT on basis already withdrawn on suppliers to self financed retailer after cessation of trading was contrary to EC law . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 May 2022; Ref: scu.136950
Work supplied to a charity for advertising may be zero-rated if for publication.
Times 20-Dec-1996, [1996] EWHC Admin 295
Value Added Tax Act 1994 Sc8Gr15It8
Updated: 25 May 2022; Ref: scu.136843
[1996] EWHC Admin 245
England and Wales
Appeal from – Regina v Commissioners of Customs and Excise, ex Parte Kay and Co; Regina v Same, ex Parte Similar CA 10-Dec-1996
The commissioners had no power to impose time limits on retrospective refund claims. . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 May 2022; Ref: scu.136793
Keens J
[1996] EWHC Admin 257
England and Wales
Updated: 25 May 2022; Ref: scu.136805
The commissioners sought to charge VAT on subscriptions paid to an association who provided centralised support services to its members. It claimed that the fees were provided as agents for its members, and so were exempt.
[1996] EWHC Admin 129
Value Added Tax Act 1994 4(1) 94(2)(a)
Updated: 25 May 2022; Ref: scu.136677
Where there was no real transaction underlying a claim for VAT credit, no VAT credit can be claimed.
Dyson J said: ‘the words ‘to the best of their judgment’ permit the commissioners a margin of discretion in making an assessment; a taxpayer may only challenge the assessment if he can show that the commissioners acted outside the margin of their discretion, by acting in a way that no reasonable body of commissioners could do. In order to succeed, the taxpayer must show that the assessment was wrong in a material respect, and that if so, the mistake is such that the only fair inference is that the commissioners did not apply best judgment’
Dyson J
[1996] EWHC Admin 111, [2000] STC 553
England and Wales
Cited – Revenue and Customs v Dempster (T/A Boulevard) ChD 24-Jan-2008
The revenue wished to refuse a claim to set off input tax for two transactions involving the alleged purchase of software. They said the transactions were a sham.
Held: The revenue’s appeal failed.
Briggs J said: ‘the critical question . .
Lists of cited by and citing cases may be incomplete.
Updated: 25 May 2022; Ref: scu.136659
Trustees who managed a group of apartments argued that they did not themselves provide staff services to the tenants, but rather arranged for the staff to provide services to them.
Held: The contract providing cleaning and other services, by a maintenance fund for a block of flats, was a VATable supply by the Trustees who employed the staff to deliver the services. It was a service delivered by the Trustees through the medium of the employees.
The House saw a clear distinction in principle between (i) the case when the relevant expenses paid have been incurred in the course of making his own supply of services to the tenant and as part of the whole of the services rendered by him to the tenant; and (ii) the case where specific services have been supplied by an external supplier to the tenant, not to the trustees, and the trustees have merely acted as the tenants’ known and authorised representative in paying the service. Only in this second case can the amounts of the payments qualify for treatment as disbursements for VAT purposes, and on this account as constituting no part of the consideration for the trustees’ own services to the tenants.
Lord Browne-Wilkinson, Lord Slynn of Hadley, Lord Nolan, Lord Clyde, Lord Hutton
Times 17-Dec-1998, [1998] UKHL 50, [1999] 1 All ER 385, [1999] 1 WLR 174, [1999] STC 79
England and Wales
Appeal from – Trustees of the Nell Gwynn House Maintenance Fund v Commissioners of Customs and Excise CA 1996
. .
Cited – Apple and Pear Development Council v Commissioners of Customs and Excise ECJ 8-Mar-1988
Consideration means ‘everything received in return for the supply of services or the provision of services’. . .
Cited – H J Glawe Spiel- und Unterhaltungsgerate Aufstellungsgesellschaft mbH and Co KG v Finanzamt Hamburg-Barmbek-Uhlenhorst ECJ 5-May-1994
Europa The taxable amount in respect of a provision of services within the meaning of Article 11 A(1)(a) of the Sixth Directive 77/388 consists of the consideration actually received in return for the service . .
Cited – Argos Distributors v Commissioners of Customs and Excise ECJ 24-Oct-1996
VAT was payable on the value of a discount voucher only, and not on the full price of the goods. ‘According to the court’s settled case law, the taxable amount for the supply of goods or services is represented by the consideration actually received . .
Cited – Commissioners of Customs and Excise v First National Bank of Chicago ECJ 14-Jul-1998
The Bank dealt in foreign exchange, not charging a commission, but relying on the profit it made over a period between the prices at which respectively it bought and sold the currency. The Bank contended that the foreign exchange transactions were . .
Cited – Customs and Excise Commissioners v Plantiford 5-Nov-1998
The court was asked whether a sum for packing and postage which the purchaser agreed to pay had to be added to the price of the goods for the purpose of constituting the consideration for the supply of such goods by the plaintiff.
Held: the . .
Cited – Skatteministeriet v Henriksen ECJ 13-Jul-1989
Europa Article 13B(b ) of the Sixth Directive ( 77/388 ) on the harmonization of the laws of the Member States relating to turnover taxes must be interpreted as meaning that the phrase ‘premises and sites for . .
Cited – British Airways Plc v Customs and Excise Commissioners 1990
The taxpayer carried paying passengers. The travel was zero-rated. They also supplied in-flight food, which the Commissioners sought to hold taxable as a separate supply.
Held: The motives of the tax-payer and traveller were irrelevant. The . .
Cited – British United Provident Association Limited v Commissioners of Customs and Excise; etc Admn 23-Jan-1997
In determining whether what would otherwise be two supplies should be regarded as a single supply the court has to ask itself whether one element is an ‘integral part’ of the other, or is ‘ancillary’ or ‘incidental’ to the other; or (in the . .
Cited – Barratt, Goff and Tomlinson and The Law Society As Intervenor v Revenue and Customs FTTTx 20-Jan-2011
FTTTx VAT – disbursements – whether fees paid for medical records and medico-legal reports by solicitors acting for clients in personal injury and medical negligence claims disbursements and thus outside scope of . .
Lists of cited by and citing cases may be incomplete.
Updated: 23 May 2022; Ref: scu.135191
Vat – Other
[2018] UKFTT 26 (TC)
England and Wales
Updated: 23 May 2022; Ref: scu.604356
ECJ Taxation – Common System of Value Added Tax : Judgment – Reference for a preliminary ruling – Taxation – Common system of value added tax – Directive 2006/112/EC – Dissolution of a company resulting in its removal from the value added tax (VAT) register – Obligation to calculate VAT on available assets and to pay the VAT calculated to the State – Maintenance or amendment of the law existing on the date of accession to the European Union – Second paragraph of Article 176 – Effect on the right to deduct – Article 168
C-552/16, [2017] EUECJ C-552/16
European
Updated: 23 May 2022; Ref: scu.599693
Vat – Other
[2018] UKFTT 27 (TC)
England and Wales
Updated: 23 May 2022; Ref: scu.604349
Claim under carousel fraud.
Morison J
[2008] EWHC 1968 (QB)
England and Wales
Updated: 22 May 2022; Ref: scu.276488
VDT VAT – Input tax deduction – Whether relevant supplies made to the Appellant or to a third party on whose behalf the Appellant acted – Held that the documentation and the conduct of the parties after the date of the written agreement indicated that the Appellant acted as agent for the third party to receive the relevant supplies on its behalf – Appeal dismissed
[2008] UKVAT V20692
England and Wales
Updated: 22 May 2022; Ref: scu.272944
Submission of EC Sales List – failure timeously to submit – whether reasonable excuse – appeal dismissed.
[2004] UKVAT V18901
England and Wales
Updated: 22 May 2022; Ref: scu.230222
[2003] UKVAT V18457
England and Wales
Updated: 22 May 2022; Ref: scu.221384
Consideration means ‘everything received in return for the supply of services or the provision of services’.
Advocate General Slynn
C-102/86, R-102/86, [1988] EUECJ R-102/86, [1988] STC 221
European
Cited – Nell Gwynn House Maintenance Fund v Commissioners of Customs and Excise HL 15-Dec-1998
Trustees who managed a group of apartments argued that they did not themselves provide staff services to the tenants, but rather arranged for the staff to provide services to them.
Held: The contract providing cleaning and other services, by a . .
Cited – Revenue and Customs v Debenhams Retail Plc CA 18-Jul-2005
The store introduced a system whereby when a customer paid by credit card, the charges made to them for card handling were expressed as a separate amount on the receipt. The store then said that VAT was payable only on the net amount allocated to . .
Cited – Airtours Holidays Transport Ltd v Revenue and Customs SC 11-May-2016
The court was asked whether the appellant, Airtours Holidays Transport Ltd (formerly MyTravel Group plc), was entitled to recover, by way of input tax VAT charged by PricewaterhouseCoopers LLP in respect of services provided by PwC and paid for by . .
Lists of cited by and citing cases may be incomplete.
Updated: 22 May 2022; Ref: scu.134390
Europa An action by the Commission pursuant to Article 169 of the Treaty against a Member State for failure to fulfil its obligations, the bringing of which is a matter for the Commission in its entire discretion, is objective in nature. In the context of the balance of powers between the institutions laid down in the Treaty, it is not for the Court to consider what objectives are pursued in such an action. Its role is to decide whether or not the Member State in question has failed to fulfil its obligations as alleged.
The identification of ‘cleary defined social reasons’ for which certain reduced rates and exemptions from value-added tax may be retained on a transitional basis pursuant to the last indent of Article 17 of the Second Directive and Article 28 (2) of the Sixth Directive is in principle a matter of political choice for the Member States and can be the subject-matter of supervision at the Community level only in so far as, by distorting that concept, it leads to measures which because of their effects and their true objectives lie outside its scope. Since, under the general scheme of value-added tax, the final consumer is the person who acquires goods or services for personal use, as opposed to an economic activity, and thus bears the tax, the second condition laid down in those provisions for the retention of certain reduced rates and exemptions, that is to say that they must be ‘for the benefit of the final consumer’ must in the light of the social purpose of Article 17 be understood as meaning that the beneficiary must not use exempted goods or services in the course of an economic activity. The provision of goods or services at a stage higher in the production or distribution chain which is nevertheless sufficiently close to the consumer to be of advantage to him must also be considered to be for the benefit of the final consumer as so defined.
‘With regard to buildings intended for housing, the Commission’s arguments cannot be upheld. The measures adopted by the United Kingdom to implement its social policy in housing matters, that is to say, facilitating home ownership for the whole population, fall within the purview of ‘social reasons’ for the purposes of the last indent of article 17 of the Second Directive.’
Advocate General Darmon
C-416/85, [1990] 2 QB 130, [1988] EUECJ C-416/85, [1988] STC 456
Cited – Her Majesty’s Commissioners of Customs and Excise v Zielinski Baker and Partners Limited HL 26-Feb-2004
The commissioners sought to charge to VAT charges for works which had been carried out to a building within the curtilage of a listed building. The taxpayer sought zero-rating.
Held: The outbuilding to which alterations were made must have . .
Cited – Revenue and Customs v Jacobs CA 22-Jul-2005
The taxpayer had converted a former residentional boarding school into a substantial private residence. He had sought to claim over andpound;300,000 VAT inputs. The Commissioners appealed the finding that he was so entitled.
Held: ‘works . .
Cited – Mason v Boscawen ChD 18-Dec-2008
The landlord had opted to charge VAT on part of the rent. The tenant fell into arrears and now challenged a notice to quit which included the VAT. The court was asked what constituted ‘rent’ for the purposes of a demand for rent founding a notice to . .
Lists of cited by and citing cases may be incomplete.
Updated: 22 May 2022; Ref: scu.134303
Procedure – application for late appeal – no good explanation – refused – evidence as expert – no – VAT – suppression of takings – best judgment – appeal dismissed – Income Tax – – best judgment – appeal dismissed – penalties – appeals allowed in part
[2020] UKFTT 455 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.656856
This appeal concerns the proper classification for VAT purposes the supplies made by the Appellant. The activities in question are the organisation by the Appellant of various competitive football and netball leagues and the supply of pitches for these league matches to be played upon. There is a dispute as to the proper description of these activities.
[2020] UKFTT 438 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.656857
VAT – default surcharge – appeal dismissed
[2014] UKFTT 146 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521699
FTTTx VAT – Application for permission to appeal out of time – Value Added Tax Act 1994, s. 83G(1) and (6) – Application allowed in part
[2014] UKFTT 549 (TC)
England and Wales
See Also – Romasave Property Services Ltd v Revenue and Customs FTTTx 26-Apr-2013
FTTTx VAT – application for permission to make late appeal – permission refused . .
Lists of cited by and citing cases may be incomplete.
Updated: 22 May 2022; Ref: scu.526949
FTTTx Vat – Input Tax : Evidence for Claim – VALUE ADDED TAX – assessments – non-attendance by Appellant – whether evidence to show that assessments excessive or incorrect – no – appeal dismissed
[2016] UKFTT 793 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.574004
FTTTx VAT – Zero rating- whether camper vans converted from VW T5 motor vans supplied to disabled customers by appellant were adapted ‘permanently and substantially’ to enable a disabled person who usually used a wheel chair ‘to enter and drive or otherwise be carried in’ the vehicle for the purposes of Note 5L to Item 2A Schedule 8 Group 12 VATA 1994 – combination of adaptations consisting of ambulance ramp fitting strip and swivel seats fulfilled criteria – appeal allowed
[2014] UKFTT 110 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521675
VAT default surcharge – insufficiency of funds – CIS refund due from HMRC to Appellant – whether reasonable excuse – no – whether penalty disproportionate – no – Appeal dismissed
[2014] UKFTT 91 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521688
FTTTx VAT APPEAL TO RE-INSTATE – Agricultural Flat-rate Scheme withdrawn from appellant 6 July 2011- appellant’s notice of appeal dated 3 December 2011-appellant taken no active part in proceedings – case struck out 10 June 2013 – appellant sort to re-instate -doubt as to date when strike out direction received- appeal allowed – unless directions issued.
[2014] UKFTT 47 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521669
VAT – default surcharge – CIS deductions wrongly made by contractors – request made to HMRC for repayment – repayment made after the due date for VAT and on the same basis as CIS deductions properly made – whether reasonable excuse – whether within the Steptoe exception – yes to the extent that HMRC were holding incorrectly deducted CIS – appeal allowed in part
[2014] UKFTT 61 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521696
VAT – MTIC fraud – whether ‘contra-trades’ subject to rule in Kittel – yes – whether knowledge of fraud – yes – appeal dismissed
[2014] UKFTT 129 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521683
VAT Registration threshold exceeded – minimum penalty imposed – whether reasonable excuse? – no – f.A. 2008 schedule 41 – appeal refused.
[2014] UKFTT 63 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521695
FTTTx VAT – retailer vouchers – delivery to customers as part of newspaper sales promotional scheme – whether articles 3 and 5 of the Value Added Tax (Supply of Services) Order 1993 apply to impose an output tax liability by reference to the cost of the vouchers – whether the vouchers were used for a purpose other than a purpose of the business of the Appellant – held no – preliminary issue decided in favour of the Appellant
[2014] UKFTT 116 (TC)
Value Added Tax (Supply of Services) Order 1993 3 5
England and Wales
Updated: 22 May 2022; Ref: scu.521664
FTTTx VAT – application for permission to make late appeal – permission refused
[2013] UKFTT 267 (TC)
England and Wales
See Also – Romasave (Property Services) Ltd v Revenue and Customs FTTTx 3-Jun-2014
FTTTx VAT – Application for permission to appeal out of time – Value Added Tax Act 1994, s. 83G(1) and (6) – Application allowed in part . .
See Also – Romasave (Property Services) Ltd v Revenue and Customs UTTC 27-May-2015
Existence of Discretion to hear late Appeal
VAT – whether assessments were duly notified to the taxpayer – VATA 1994, s 73(2), s 83G and s 98 – Interpretation Act, s 7 – Companies Act 2006, s 1139(1) – whether notification of assessment invalidated by error on the face of the notice of . .
Lists of cited by and citing cases may be incomplete.
Updated: 22 May 2022; Ref: scu.503571
FTTTx VAT – registration – whether Appellant liable to register in respect of earnings from part-time judicial appointment in absence of earnings from practice as barrister – classification previously for income tax purposes as self-employed – EC Directive 2006 arts 9, 10 – held, not a taxable person so not liable to register – appeal allowed
[2012] UKFTT 144 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.451977
FTTTx DEFAULT SURCHARGE – appeal against all surcharges from 06/06 to 12/12 on basis that appellant could only pay by instalments due to difficulties from clients’ late payments. – lack of funds was not a reasonable excuse – appeal dismissed.
[2014] UKFTT 84 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521659
FTTTx VAT – default surcharge – reasonable excuse – serious illness of administrator – proportionality -2 days late – held – reasonable excuse for earlier of two periods -but not for later period – penalty not disproportionate by reference to Total Technology.
[2014] UKFTT 140 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.521662
VAT surcharges – time to pay agreements – entered into after due dates – no reasonable excuses
[2011] UKFTT 805 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.450952
ZERO-RATING – Exports – Pharmaceutical goods exported to Nigeria and Ghana – Evidence of export – VAT Directive 2006/112/EC Art 131, 146 – VAT Act 1994 s.30 – VAT Regs 1995 reg 129 – Notice 703 – Appeal allowed in part
INPUT TAX – Payment of invoices – Whether paid within 6 months – VAT Act 1994 s.26A – VAT Regs 1995 reg 170, 173J – Appeal allowed in part
[2012] UKFTT 126 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.451949
VAT – DEFAULT SURCHARGE – Appellant failed to submit its VAT return on time- did the Appellant have a reasonable excuse – No – Appeal dismissed
[2012] UKFTT 117 (TC)
England and Wales
Updated: 22 May 2022; Ref: scu.451951
(The Dutch Potato case) A farmers’ cooperative owned a refrigerated potato store. During 1975 and 1976 it came to be unnecessary, because it was planning to sell the store, to levy the usual storage charges on its members. Dutch tax officials claimed that there was nevertheless consideration for their use of the store in the form of a reduction in the value of their shares in the co-operative.
Held: The tax official’s case failed. Three principles applied. There must be a direct link between the service provided and the consideration received; the consideration must be capable of being expressed in money; and thirdly, ‘that such consideration is a subjective value since the basis of assessment for the provision of services is the consideration actually received and not a value assessed according to objective criteria’.
Advocate General Warner
[1981] ECR 445, C-154/80, R-154/80, [1981] EUECJ R-154/80
European
Cited – Lex Services plc v Her Majestys Commissioners of Customs and Excise HL 4-Dec-2003
When taking a car in part exchange, the company would initially offer the correct market value. If the customer wanted, the company would agree a higher price. When cars were returned, the company at first reclaimed the VAT on the re-purchase price, . .
Cited – Revenue and Customs v Debenhams Retail Plc CA 18-Jul-2005
The store introduced a system whereby when a customer paid by credit card, the charges made to them for card handling were expressed as a separate amount on the receipt. The store then said that VAT was payable only on the net amount allocated to . .
Cited – Airtours Holidays Transport Ltd v Revenue and Customs SC 11-May-2016
The court was asked whether the appellant, Airtours Holidays Transport Ltd (formerly MyTravel Group plc), was entitled to recover, by way of input tax VAT charged by PricewaterhouseCoopers LLP in respect of services provided by PwC and paid for by . .
Lists of cited by and citing cases may be incomplete.
Updated: 21 May 2022; Ref: scu.133088
Vat – Validity of European Commission Implementing Regulation (EU) No. 282/2011 – Application for reference to CJEU under art 267 TFEU – Validity of European Commission Implementing Regulation – test to be applied – Order for referral – Interpretation of Council Implementing Regulation – test to be applied – application for reference refused
[2020] UKFTT 499 (TC)
England and Wales
Updated: 21 May 2022; Ref: scu.656874
ECJ (Judgment) Failure to fulfill obligations – Tax on value added – Directive 2006/112 / EC – Exemptions – Article 132, paragraph 1, sub m) – Services closely associated with sport or physical education – exemption for the leasing of berths and sites for storage of boats for water sports association members through navigation or recreation activities that can not be equated with sport or physical education – exemption from income limited to members of watersports associations that do not employ staff for the provision of services – Excluded – Article 133, first paragraph d)
ECLI:EU:C:2016:118, [2016] EUECJ C-22/15
European
Updated: 20 May 2022; Ref: scu.560478
An Organ Grinder receiving donations was not Vatable on those receipts. There was no legal relationship with donors.
A supply of services is effected ‘for consideration’ within the meaning of Article 2(1) of the Sixth Council Directive (77/388) on the harmonization of the laws of the Member States relating to turnover taxes, and hence is taxable, only if there is a legal relationship between the provider of the service and the recipient pursuant to which there is reciprocal performance, the remuneration received by the provider of the service constituting the value actually given in return for the service supplied to the recipient.
Those conditions are not fulfilled in the case of an activity consisting in playing music on the public highway, for which no remuneration is stipulated, even if the musician solicits money and receives sums, in the form of donations, whose amount is however neither quantified nor quantifiable.
Times 29-Mar-1994, [1994] ECR 1-743, C-16/93, [1994] EUECJ C-16/93
European
Cited – Town and Country Factors Ltd v Commissioners of Customs and Excise ECJ 17-Sep-2002
The company organised ‘Spot the Ball’ competitions. The company did not accept a legal obligation to pay out, being bound in honour only, but in fact always did so. They claimed that there was no supply of services.
Held: The Directive . .
Cited – Airtours Holidays Transport Ltd v Revenue and Customs SC 11-May-2016
The court was asked whether the appellant, Airtours Holidays Transport Ltd (formerly MyTravel Group plc), was entitled to recover, by way of input tax VAT charged by PricewaterhouseCoopers LLP in respect of services provided by PwC and paid for by . .
Lists of cited by and citing cases may be incomplete.
Updated: 20 May 2022; Ref: scu.89908
Where original VAT invoice was lost a duplicate should be accepted for refund claim even though from other member state where there was no doubt about the transaction, and the loss was not the fault of the taxpayer, and no risk of double reclaim of VAT duty.
Gazette 09-Sep-1998, C-361/96, Ecj/Cfi Bulletin 15/98, 7, [1998] EUECJ C-361/96
European
Updated: 20 May 2022; Ref: scu.89369
The Vatable amount is based on what a purchaser pays ignoring any commissions.
Ind Summary 20-Sep-1993, Times 22-Jul-1993, C-18/92, C-18/92, [1993] EUECJ C-18/92
Cited – Revenue and Customs v Debenhams Retail Plc CA 18-Jul-2005
The store introduced a system whereby when a customer paid by credit card, the charges made to them for card handling were expressed as a separate amount on the receipt. The store then said that VAT was payable only on the net amount allocated to . .
Lists of cited by and citing cases may be incomplete.
Updated: 20 May 2022; Ref: scu.88964
The local authority had reclaimed input tax against invoices it received from builders. They were disallowed because the building constructed was an exempt supply. Although the section allowed the authority to set off VAT against invoices for supplies not made for any business of the taxpayer. The arrangements suggested that they had acted on terms applicable to traders generally rather than any special situation applicable to local authorities, which was the purpose of the section as it derived from the Directive.
Patten J
Gazette 04-Oct-2001
England and Wales
Updated: 19 May 2022; Ref: scu.166231
The fact that motor vehicles might in some circumstances be only capable of being used within a person’s trade or business, did not mean that a member state was disallowed from excluding the right to deduct VAT from payments made on the purchase of such items.
Times 15-Oct-1999, C-305/97, [1999] EUECJ C-305/97
European
Reference – Royscott Leasing Ltd and Another v Commissioners of Customs and Excise; Allied Domecq Plc v Same; T C Harrison Group Ltd v Same CA 23-Nov-1998
The court has the power to with draw a reference of a case to the European Court of Justice. This should only normally be done, however, where it had become clear that the reference would no longer serve any useful purpose. . .
Lists of cited by and citing cases may be incomplete.
Updated: 19 May 2022; Ref: scu.88905
Mere holding of financial bonds is not economic activity attracting VAT.
Times 13-Feb-1997, [1997] EUECJ C-80/95
European
Updated: 19 May 2022; Ref: scu.81249
The taxpayer ran several gaming clubs under a license authorising roulette type games. He was assessed to VAT, calculated on a probability basis.
Held: In general VAT was recoverable on unlawful supplies, including unlawful gaming arrangements, but where the national legislation exempted lawful arrangements it could not be applied to unlawful versions. Fiscal neutrality prevented unlawful gaming being treated differently. If gaming was VAT exempt, so also must be unlawful gaming.
Times 02-Jul-1998, Gazette 09-Sep-1998, C-283/95, Ecj/Cfi Bulletin 15/98, 16, [1998] EUECJ C-283/95
Updated: 19 May 2022; Ref: scu.80572
A reduction assessment made by the Commissioners, of the VAT due, which had made been under their powers to make such ‘according to their best judgment’, could not be challenged at the VAT Tribunal on the exercise of that best judgment.
Times 28-Dec-1998, Gazette 10-Feb-1999
Value Added Tax Act 1994 73(1)
Updated: 19 May 2022; Ref: scu.80292
Credit note can be used as evidence of VAT invoice.
Times 20-Nov-1997, C-141/96, [1997] EUECJ C-141/96
European
Updated: 19 May 2022; Ref: scu.80539
It was open to a member state to disallow reclaim of VAT on a motor vehicle even though it was the very tool of the owners trade. State had right to retain regulations predating the Council Directive disallowing such allowances.
Gazette 09-Sep-1998, C-43/96, Ecj/Cfi Bulletin 16/98, 27
Updated: 19 May 2022; Ref: scu.80242
The fact that a service was provided by a doctor did not mean of itself that it came within Art 13 of the Directive. The test was whether the service was part a provision of care by diagnosing and treating some diseases or disorder. The carrying out of investigations to establish genetic differences, which was to provide evidence in paternity proceedings in a court was not part of such a process, and so did not attract exemption from VAT.
Times 24-Oct-2000, C-384/98
Updated: 19 May 2022; Ref: scu.79768
A ‘taxable supply’ within the Act did not include an out-of-country supply, even if, had that supply been made within the UK, it would have been taxable. Advertising services provided a German company were deemed to have been made in Germany, and was out-of-country. Other services of the applicant were exempt, and therefore the company was unable to deduct tax for payments of VAT residual inputs, for supplies purchased and used for the general purposes of the taxable person. The method chosen for calculating the apportionment excluded out-of-country supplies.
Lord Slynn of Hadley Lord Cooke of Thorndon Lord Hope of Craighead Lord Millett Lord Scott of Foscote
Times 01-Jun-2001, Gazette 21-Jun-2001, [2001] UKHL 28, [2001] 1 WLR 1187, [2001] STC 891, [2001] STI 848, [2001] BTC 5258, [2001] BVC 333, [2001] 3 CMLR 5
Value Added Tax (Place of Supply of Services) Order 1992 (1992 No 3121)
Updated: 19 May 2022; Ref: scu.79390
Where a company was delivering goods to its customers by sending them via the Royal Mail passing on to the customer only the direct cost charged to it by Royal Mail, there was no obligation to levy VAT on that charge. The items delivered were postal packets, and the arrangement was in effect that the company acted as the agent of the customer in paying on the carrier’s charges.
Times 10-Feb-2000, [2000] EWCA Civ 26
Value Added Tax Act 1994 31 Sch 9 Grp 3
England and Wales
Updated: 19 May 2022; Ref: scu.79393
ECJ Article 26(2) of the Sixth Directive 77/388 on the harmonization of the laws of the Member States relating to turnover taxes is to be interpreted as meaning that, where a tour operator established in one Member State provides services to travellers through the intermediary of a company operating as an agent in another Member State, VAT is payable on those services in the latter State if that company, which acts as a mere auxiliary organ of the tour operator, has the human and technical resources characteristic of a fixed establishment. Although the place where a supplier’s business is established is the main fiscal point of reference, that reference would not lead to a rational result in that it takes no account of the actual place where the tours are marketed. On the other hand, the alternative approach of levying tax at the place of the fixed establishment from which those services are supplied, because it takes account of the possible diversification of travel agents’ activities in different places within the Community and avoids the distortions of competition which might arise from reliance on the place where the supplier has established his business, in that undertakings trading in a Member State might be encouraged to establish their businesses in a Member State in which the services in question were exempted, is based on the actual economic situation, which constitutes a fundamental criterion for the application of the common system of value added tax.
Times 24-Feb-1997, C-260/95, [1997] EUECJ C-260/95
Updated: 19 May 2022; Ref: scu.79380
(Judgment) It was open to member states to refuse to allow claim VAT input reclaims on articles purchased for transport which constituted the very tool of the trade of a taxpayer. Driving instructors may not reclaim VAT on their transport.
Times 02-Jul-1998, C-43/96, [1998] EUECJ C-43/96
Council Directive 77/388/EEC, EC Treaty 169
European
Updated: 19 May 2022; Ref: scu.79302
The appellants sold a system protecting credit card holders against the consequences of loss or theft. They claimed that it was insurance and exempt from VAT. The commissioners said it was a service and vatable. The card provided a range of services for those who had lost a card, and laid off the costs against their own re-insurance. The European Court had defined insurance as the payment of a premium, to provide the insured, in the event of materialisation of the risk covered, with the service agreed when the contract was concluded. The commissioners held that two services were included, one of insurance, and one of the registration of an individual’s card and other details.
Held: The dominant purpose of the contract was for insurance. Others were ancillary or minor. (Slynn) ‘the court’s task is to have regard to the ‘essential features of the transaction’ to see whether it is ‘several distinct principal services’ or a single service and that what from an economic point of view is in reality a single service should not be ‘artificially split’. It seems that an overall view should be taken and over-zealous dissecting and analysis of particular clauses should be avoided.’ The court should asking itself ‘what is the essential feature of the scheme or its dominant purpose – perhaps why objectively people are likely to want to join it’.
Lord Slynn of Hadley Lord Jauncey of Tullichettle Lord Nolan Lord Steyn Lord Hoffmann
Times 06-Feb-2001, Gazette 01-Mar-2001, [2001] UKHL 4, [2001] 2 ALL ER 143, [2001] 2 WLR 329, [2002] 1 AC 202
Sixth Council Directive (77/388/EEC) (OJ 1977 L145/1), Value Added Tax Act 1983 17(1)
England and Wales
Referred back – Card Protection Plan Ltd v Commissioners of Customs and Excise ECJ 25-Feb-1999
A company procuring insurance purchases for credit card protection was as exempt from VAT as was the insurer. A provision which restricted the ability to claim such exemption to those registered as insurers under national was invalid under European . .
Referred back – Card Protection Plan Ltd v Commissioners of Customs and Excise ECJ 25-Feb-1999
A company procuring insurance purchases for credit card protection was as exempt from VAT as was the insurer. A provision which restricted the ability to claim such exemption to those registered as insurers under national was invalid under European . .
Cited – College of Estate Management v Commissioners of Customs and Excise ChD 13-Nov-2003
The college appealed a finding that the supply of course manuals to its students was part of its exempt rather than zero-rated supply.
Held: ‘Once it is decided that there is a single supply from an economic view which should not be . .
Cited – College of Estate Management v Commissioners of Customs and Excise CA 11-Aug-2004
When offering courses to distance learning students, the College offered materials for the courses. As part of the course this supply would be exempt, as books, the supply would be zero-rated, but the taxpayer would be able to reclaim its VAT . .
Lists of cited by and citing cases may be incomplete.
Updated: 19 May 2022; Ref: scu.78887
FTTTx VALUE ADDED TAX – reduced rate on supplies of energy-saving materials – weather stripping services supplied with other services generally related to renovation of windows – whether composite or separate supplies – held that where weather stripping services were invoiced for separate prices they were separate supplies, otherwise they were elements of composite supplies not attracting the reduced rate – penalty considered – held that in relation to all but one of the periods assessed the inaccuracy was not careless with two minor exceptions – mitigation reduction percentages also increased – decision in principle – appeal allowed in part
[2014] UKFTT 518 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.526830
FTTTx VALUE ADDED TAX – refurbishment of nursing home premises – lease of premises by company to subsidiary – services provided under separate agreement – whether single exempt supply of property together with services or independent supplies of property and services – held, single composite exempt supply of property and services – similar conclusion on basis of manner in which arrangements implemented in practice – deductibility of input tax – held none of input tax on construction costs attributable to taxable supplies – appeal dismissed
Procedure – application for late admission of appeals granted and some appeals consolidated with main appeal
[2013] UKFTT 447 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.515228
VAT – VAT incorrectly charged – adjustment to amount of consideration – whether Regulation 38 applies to allow refund of incorrect VAT – no – whether letter from HMRC to adviser is a valid notice of assessment – no – discretion of Tribunal to award costs where notice of appeal was to VAT and Duties Tribunal – Regulation 38, VAT Regulations 1995 – Section 73 VAT Act 1994 – Sch 3 Transfer of Tribunal Functions and Revenue and Customs Appeals Order 2009
[2014] UKFTT 425 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.526838
FTTTx VAT – exemption for medical care – whether applies to services provided by company acting as a principal in providing medical doctors on a locum basis to hospitals – no – Article 132(1)(c) Principal VAT Directive – Schedule 9 Group 7 Item 5 Value Added Tax Act 1994 – appeal dismissed
[2013] UKFTT 432 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.515225
FTTTx Value added tax – application by Appellant for an extension of time to appeal – cross application by HMRC to strike out appeal – omission by HMRC to offer a reconsideration – delay by Appellant in lodging appeal – whether reasonable excuse – no – application refused and appeal struck out
[2013] UKFTT 460 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.515217
FTTTx VAT – input tax – involvement in MTIC transactions – denial of repayment on Kittel grounds – position of contra-trading transactions after Mahageben – whether taxpayer knew or should have known of connection to fraudulent VAT evasion – appeal dismissed
[2013] UKFTT 448 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.515222
FTTTx VAT – MTIC – preliminary hearing – application to admit late evidence – allowed in part subject to undertaking – application for disclosure – allowed in part – costs – dismissed
[2011] UKFTT 649 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.449505
FTTTx VALUE ADDED TAX – Section 3 and Schedule 1 VAT Act 1994 – Failure to register in respect of taxable supplies – co-operation and personal circumstances considered – whether further reduction in penalty is justified – Appeal dismissed.
[2011] UKFTT 22 (TC)
England and Wales
Updated: 19 May 2022; Ref: scu.428204