Quality Engines Direct Ltd v Revenue & Customs (VAT � whether or not the appellant made supplies of silver ingots � no � appeal allowed)

VAT � Value Added Tax Act 1994, sections 4 and 73(1) � whether or not the appellant made supplies of silver ingots � no � appeal allowed

Sitting in public at Alexandra House, 14-22 The Parsonage, Manchester, M3 2JA on 8 December 2017

Mr Bernard Haley, Presenting Officer, instructed by the General Counsel and Solicitor to HM Revenue and Customs, for the Respondents

This is an appeal against a VAT assessment dated 4 August 2016 in the sum of �60,052 for the period 04/16 (�the Assessment�) issued pursuant to section 73(1) of the Value Added Tax Act 1994 (�VATA 1994�). The Assessment was in respect of two supplies of silver ingots in the total sum of �360,374 (�the Silver�). The dispute is a narrow one: whether or not the appellant, Quality Engines Direct Ltd (�QEDL�) supplied the Silver.

The broad factual background was not in dispute.� QEDL carries on business in the renovation and restoration of engines for road vehicles. It operates from a garage in Oldham and has been registered for VAT since 1 December 2009. The director of QEDL is Mr Jahinger Rafiq. The shareholders of QEDL are Mr Rafiq (with 25 shares), Mr Rafiq�s father (with 75 shares) and Mr Rafiq�s mother (with the remaining 75 shares).