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VALUE ADDED TAX - Schedule 24 Finance Act 2007 - penalty for inaccuracy in VAT returns - personal liability notice on director - was there an inaccuracy in the VAT returns? - company buying and selling of alcohol held in warehouses in France and Germany - was place of supply the UK? - burden of proof on HMRC - held: not proven that place of supply was UK - appeal allowed
The hearing took place on 8-10 February 2021. The form of the hearing was V (video) on the HMCTS Video Hearings Service . �A face to face hearing was not held due to public health concerns related to the coronavirus pandemic. The documents to which we were referred were nine lever arch files and an authorities etc electronic bundle of 214 pdf pages, prepared by the respondents.
Prior notice of the hearing had been published on the gov.uk website, with information about how representatives of the media or members of the public could apply to join the hearing remotely in order to observe the proceedings.� As such, the hearing was held in public.
Mr R Macleod, advocate, instructed by the Office of the Advocate General, for the Respondents
The appeal concerned the validity of a personal liability notice (the � PLN �) making the appellant (� Mr Zaman �) liable for 100% of an �inaccuracy� penalty (the � penalty �) of just over �1.7 million charged to Zamco Limited (� Zamco �), a company of which the appellant was sole director and shareholder.
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