TC09590 - [2025] UKFTT 00878 (TC)

Fecha: 25-Jun-2025

Introduction &Grounds of Appeal

Introduction &Grounds of Appeal

In this decision when we refer to the Appellant we mean Redrose Payroll Ltd (“RRP”) and vice versa. When we refer to the Respondents we mean The Commissioners for His Majesty’s Revenue and Customs (“HMRC”), and vice versa.

The Appellant appeals four decisions:

(1)

a decision dated 20 May 2022 to de-register the Appellant as its VAT registration had been used solely or principally for fraudulent purposes (i.e. the Ablessiobasis or decision);

(2)

a decision dated 20 May 2022 denying the Appellant the right to deduct input tax as it knew or should have known that it was participating in transactions connected with the fraudulent evasion of VAT (i.e. the Kittelbasis or decision);

(3)

a VAT assessment dated 20 May 2022, assessing a total of £7,191,003 in VAT in respect of periods 05/20 to 11/21 inclusive( the “Assessment”); and

(4)

a penalty issued to the Appellant pursuant to section 69C, Value Added Tax Act 1994 (the “VATA”) in the amount of £2,157,300.90(the “Penalty”).