TC09617 - [2025] UKFTT 01018 (TC)

first, was there persuasive direct evidence of knowledge on the part of Mr Smith (and therefore Deos) that the purchases were connected with fraudulent VAT evasion?

if not, then, on the evidence before the Tribunal, were the circumstances in which the purchases were undertaken sufficiently suspicious, such that it could be inferred that Mr Smith knew the purchases were connected with fraudulent VAT evasion (despite the direct evidence of such knowledge being unpersuasive)? and, finally

if the circumstances of the purchases were not suspicious to that degree, were they nonetheless sufficiently suspicious that a reasonable businessperson would have known that they were connected with fraudulent VAT evasion (even if, on the evidence before the Tribunal, Mr Smith himself did not have this knowledge); put differently, was there was no reasonable explanation for the circumstances in which the purchases were undertaken, other than connection with VAT fraud?