TC09596 - [2025] UKFTT 00895 (TC)

Whether, for VAT purposes, the supplies of fitting services made to customers following the referral to the fitter by the Appellant were supplies made (i) by the self-employed carpet fitters who performed the services, or (ii) by the Appellant as a single supply of flooring and fitting (“the Supply Issue”); and

Whether the Assessments, or alternatively some of them, should be quashed on the basis that they were made by HMRC in breach of a legitimate expectation on the part of the Appellant that HMRC would take no such retrospective action (“the Legitimate Expectation Issue”). This issue gives rise to a question as to the scope of the jurisdiction of the Tribunal, and the application of the doctrine of legitimate expectation.