TC09590 - [2025] UKFTT 00878 (TC)

Ms Shabbir was, at all relevant times, the Appellant’s Finance Manager. She holds a First-Class Honours degree in Business Accounting and has worked in finance roles since 2014. She joined Wise Move Consulting in 2016 and transitioned to RRP in 2019, following its incorporation by Janet and Stuart Walmsley.

Ms Shabbir described her responsibilities at RRP as encompassing payroll processing, bank reconciliations, VAT returns, and the preparation of management accounts. She stated that RRP relied on the services of its external accountants, Harold Sharp (“HS”), who had full access to RRP’s Xero accounting system and were involved in reviewing transactions and advising on VAT treatment. She maintained that no concerns were raised by HS in relation to the transactions between RRP and WM.

Ms Shabbir confirmed that RRP’s role was limited to back-office and payroll support, and that the ultimate recipients of labour were identified by WM, not by RRP. She did not suggest that RRP had any direct contractual relationships with those recipients. She further stated that instructions regarding invoicing and service provision were received from individuals named Ian and Charlie, neither of whom, on her account, were directors of WM. She did not indicate that any verification of their authority was undertaken.

In relation to the VAT deregistration of WM, Ms Shabbir acknowledged that RRP continued to pay VAT on invoices issued by WM between 4 January and 26 January 2022, when formal notification of the deregistration was received. She stated that these payments were made in good faith and without knowledge of the deregistration, and that advice was sought from HS upon discovery of the issue.

Ms Shabbir did not give evidence of any independent due diligence undertaken by RRP into the commercial standing or VAT compliance of WM, nor did she address any prior warnings or educational efforts by HMRC directed at Mrs Walmsley.

Ms Shabbir concludes her evidence by saying that she had no reason to suspect that the transactions between RRP and WM were connected with fraud.