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Parties submissions
Parties submissions
3KH contends that it has provided substantive evidence that it was RM who was responsible for the operation of TSL in the period April 2017 to August 2018 and as such it has no liability to account for output tax in connection with the sales made from that premises. 3KH also contend that the input tax it has claimed was input tax incurred or was committed to incur in connection with the business it intended to operate before plans changed and the arrangements with RM/AN were put in place.
HMRC contend that the evidence available supports a reasonable conclusion that 3KH operated TSL.
- Heading
- Introduction
- Brief factual and procedural background
- Burden of Proof
- Evidence
- Parties submission
- Findings of fact
- Evidence
- Parties submissions
- Findings of fact
- Best Judgement Issue
- Evidence
- Parties submissions
- Findings of fact
- VAT Quantum Issue
- Parties submissions
- Evidence
- Input Tax Issue
- Discussion
- Works on premises in Leicester
- 7 Wilmslow Road
- Vehicle hire invoices
- Birmingham Hotels invoices
- Discovery Issue
- Findings of fact
- Deliberate issue
- Parties submissions
- Findings of fact
- Participation Issue
- PLN Issue
- Findings of Fact
- Mitigation Issue
- Parties submissions
- Findings of fact
- Conclusions