TC09665 - [2025] UKFTT 01252 (TC)

Fecha: 26-Ago-2025

Invoices

Invoices

31.

The primary evidence required by Regulation 29(2)(a) is a VAT invoice from the supplier. The VAT invoice is the document required to be issued by the supplier in accordance with Regulation 13. That document must contain the information and otherwise comply with the conditions set out in Regulation 14.

32.

During the check HMRC requested a number of VAT invoices from the Appellant, initially in respect of the five largest supplies but then in respect of other purchases. We were taken in the hearing to the following invoices:

(1)

Universal Granite UK - dated 10 June 2021 for £2,881.90 plus £576.38 VAT. Ms Wilkinson’s criticism was that it predated EDR and the VAT number was wrong.

(2)

B&M Henderson – dated 16 April for £1,302.40 plus £260.48 VAT. Ms Henderson pointed out there was no year in the date. The invoice refers simply to “refurbishment” so there is no indication as to what the goods were used for. Further, HMRC could not work out whether it had been paid and whether those goods were held in stock at EDR.

(3)

Brickies - dated 22 February 2022 for £638.82 plus £127.76 VAT. Ms Wilkinson’s criticism was that it predated EDR and was invoiced to the Appellant at a different address.

(4)

Brickies - dated 9 May 2022 for £3,697.99 plus £739.60 VAT. Ms Wilkinson’s criticism was that the invoice predated EDR and there was no indication the purchase was connected the Cromley Road. Further this was part one of a longer invoice which had not been sent to HMRC. We take Ms Wilkinson’s reference to be to the invoice being “page 2”, the items on the invoice total £339.36 plus VAT but the total is £3,697.99 plus VAT.

(5)

Brickies - dated 15 July 2022 for £1,117.45 plus £223.49 VAT. Ms Wilkinson’s criticism was that the delivery address was Heaton Moor Road which was an odd address. Further, it predated EDR.

(6)

Brickies – dated 10 August 2022 for £5.549.76 plus £1,109.95 VAT. Ms Wilkinson’s criticism was that this was expressly stated not to be VAT invoice.

33.

These invoices, represented by a rough estimation of both parties at the hearing some 25-40% of the input tax being reclaimed. We understand that there were no other invoices produced by the Appellant to HMRC to support its claim.