Orchestrated overall scheme to defraud HMRC
Orchestrated overall scheme to defraud HMRC
It also follows from what we have said above HMRC are unable to establish that the Appellant knowingly participated in an overall and orchestrated scheme to defraud the Respondents. The lack of due diligence is insufficient to establish knowledge on the balance of probabilities.
Other issues
Given our findings on the Kittel decision it is unnecessary for us to go on to consider the Albesio, Assessment or Penalty decisions.
- Heading
- Introduction &Grounds of Appeal
- THE LAW
- THE ISSUES
- THE EVIDENCE & FINDINGS OF FACT
- The Respondents’ evidence
- The Appellant’s evidence
- Mrs Janet Walmsley
- Charlie Vause, Ian Hamilton and WM
- Accountants
- VAT deregistration
- Knowledge of connection with fraud
- Ms Katijah Shabir
- Discussion
- Orchestrated overall scheme to defraud HMRC
- Conclusions
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