Tax

E-Tel (UK) Ltd v Revenue & Customs

[2014] UKFTT TC TC03732First-tier Tribunal (Tax)2014

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Lucy Wilson-Barnes, instructed by the Solicitor and Attorney for HMRC, on behalf of the Respondents

This was a relatively simple Missing Trader or MTIC appeal in which HMRC had denied claims for input tax in respect of 57 deals undertaken by the Appellant between March and July 2006. �All of the deals involved supplies of mobile phones. The cumulative input tax in dispute was approximately �2.7 million, the detailed figures being given in paragraph 19 below.

The burden of proof falls on HMRC, so that we are required to decide whether, on the balance of probability, HMRC has demonstrated the two critical points just stated.

We will deal in two ways with the Appellant�s counsels� contentions in relation to the three issues of:

Considerable evidence was given in this case. The decisions denying input tax and the assessments to modest amounts of output tax were made in relation to the Appellant�s monthly VAT periods from 03/06 to 08/06. The case officer for the 03/06 period was Ms Jayne Holden, whilst the case officer for all the remaining periods was Ms. Angela Williams. Both gave extensive Witness Statements and both were cross-examined at some length.

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