1st 4 Report Ltd v Revenue & Customs

VALUE ADDED TAX � input tax � denial of right to deduct on grounds that the Appellant knew or should have known that the transaction was part of fraud by others � alleged MTIC � whether shown that the Appellant�s transactions connected with fraudulent evasion of VAT � yes � whether Appellant �knew or should have known� of fraud � yes � valid refusal of right to deduct � appeal dismissed

Mr Chapman, Counsel instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

Mr Richard Chapman of Counsel appeared on behalf of HMRC. Mr Ian Bridge of Counsel appeared on behalf of Report. Both produced skeleton arguments and written submissions which set out the issues to be determined by us. We were also provided with 19 lever arch files containing witness statements and documentary exhibits relied upon by both parties.

� Mr Stephen Doyle, Case Officer for HMRC responsible for the extended verification of VAT period 05/06;

� Mr Fu Lam, HMRC officer assigned to contra-trader Uni-brand Europe Limited (�Uni-Brand�);