TC09590 - [2025] UKFTT 00878 (TC)
First-tier Tribunal (Tax Chamber)

TC09590 - [2025] UKFTT 00878 (TC)

Fecha: 25-Jun-2025

Orchestrated overall scheme to defraud HMRC

Orchestrated overall scheme to defraud HMRC

76.

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

77.

Given our findings on the Kittel decision it is unnecessary for us to go on to consider the Albesio, Assessment or Penalty decisions.