TC09596 - [2025] UKFTT 00895 (TC)

The documents for the hearing, set out at para. 10 above, comprised of pleadings, documents and correspondence relating to HMRC’s enquiry and appeal correspondence. The bundle also contained the statements of the witnesses. The witnesses who gave evidence at the hearing were Mr Paul Newton (on behalf of the Appellant) and Officer Grain (of HMRC). We considered the evidence given by the witnesses to be of assistance to us in understanding the background and details regarding the supplies in this appeal. We also heard lengthy submissions from Mr Jones and Miss McArdle (as set out in their respective skeleton arguments), which we shall not repeat here. We have considered any key points of disagreement in determining the facts later.

At the conclusion of the hearing, we reserved our decision, which we now give with reasons.