TC09672 - [2025] UKFTT 01262 (TC)

HMRC have rejected the Appellant’s claim for a number of reasons, including that there was no evidence of the Appellant carrying on a business or intention to make taxable supplies. Those arguments are the subject of the main appeal but this application was made on more limited grounds. Further, the application proceeded on the assumption that the Appellant was carrying on a business and making taxable supplies but HMRC have reserved its position to make that argument at the full appeal. I have proceeded on that basis.

HMRC made this application on three grounds each ground applied to discrete groups of input tax claims and can be considered in isolation, in effect three applications to strike out parts of the Appellant’s appeal. Those grounds are:

It is not possible or appropriate to consider the large number of individual input tax claims in this application. I have therefore sought to decide this matter by category and leave it to the parties to apply to each individual claim.