TC09672 - [2025] UKFTT 01262 (TC)

It became apparent from the papers and at the hearing that the Appellant’s input tax reclaims which are the subject this application were made on a very simple, that is to say, straight forward, basis. In broad terms Mr Joseph’s position is that a cost should generate a VAT reclaim. It is also clear that Mr Joseph has not appreciated the distinction between himself and his company, the Appellant. Further, the administrative requirements of VAT record keeping and the technical conditions for recovering VAT do not appear to have been obvious to him. All of this has caused Mr Joseph considerable frustration. Nevertheless, whether or not the Appellant has valid input tax claims needs to be considered in accordance with the technical requirements of the VAT legislation.

During the course of the hearing Mr Joseph made a number of wider arguments and complaints about HMRC’s behaviour in the VAT investigation and wider issues with corporation tax and research and development credits. As I pointed out during the hearing these were not relevant to the issues in the strike out application and I therefore do not deal with them in this decision.