TC09617 - [2025] UKFTT 01018 (TC)

Fecha: 13-Jun-2025

Deos and RC

Deos and RC

54.

An individual whose initials were RC was, for a short time, engaged as a sales agent for Deos but was unsuccessful in generating sales leads during his tenure. In more detail:

(1)

Mr Smith first encountered RC in December 2021, when he was an agent working on behalf of Prestek Computing Ltd (“Prestek”);

(2)

Prestek made contact Deos as a consequence of Deos’ presence on IPT;

(3)

Deos did background checks on Prestek but not on RC personally; Deos did not consider him sufficiently senior to merit a background check;

(4)

Deos did a single transaction with Prestek, a sale of 910 Airpods in February 2022;

(5)

RC told Mr Smith that he had a lot of contacts in the industry and might be able to find customers for Deos;

(6)

From February 2022 Deos trialled an arrangement with RC: Deos sent him anonymised lists of the stock offers received from Estanza (RC was not told who Deos was buying from); RC’s task was to see if he could sell stock, and in return Deos would pay a commission on a successful sale. RC was not authorised to close a deal on behalf of Deos; any sales leads he generated would need to be reviewed and approved by Mr Smith before they could proceed;

(7)

the arrangement was not successful: RC put Deos in contact with only two counterparties of which it wasn’t already aware, both of which proved to be unreliable customers;

(8)

RC’s total compensation for his work for Deos was £550.

55.

HMRC adduced evidence as follows (although this information was not known to Deos at the time of the purchases):

(1)

RC was disqualified as a director for 10 years having been the principal behind Perfect Computing Ltd, a company that was previously denied input tax claims on Kittel grounds, having been involved in tax loss chains and stolen goods. Perfect Computing Ltd also operated as a missing trader, failing to declare acquisition tax on transactions. The company was deregistered for VAT in February 2020;

(2)

Prestek had been involved in tax loss transaction chains in which Perfect was the defaulter, which led to the denial of Prestek’s input VAT claims on Kittel grounds.