Mr Granger
Mr Granger
Mr Kane Granger (“KG”) gave evidence (by video) as to his background and his involvement with SKM. His evidence as to facts is set out in our findings of fact.
We found Mr Granger to be a credible and reliable witness and accepted his evidence as to matters of fact as set out in our findings of fact. While he is obviously a friend of Mr Feldman, we considered him to be impartial in giving his evidence. Where he was uncertain about something (e.g. the date of the visit to BTL), he said so. Where his recollection contradicted SF’s he was not afraid to stand by his recollection (e.g. whether LP had left the BTL yard before or immediately after the SKM team arrived).
- Heading
- Introduction
- summary
- Issues for determination
- Evidence and submissions
- Officer Borland
- Officer Pathak
- Mr Feldman
- Mr Granger
- Adverse inferences - Mr Perdicou
- Findings of fact
- Background – SK
- Background KG
- Background SKM
- Background SKM – Knowledge of MTIC
- SKM’s Business – control
- SKM’s business
- BTL’s business and its dealings with SKM
- Commencement of trading with SKM
- Invoices
- HMRC’s First Investigation of SKM
- SKM’s approach to Due Diligence
- HMRC’s investigation of BTL
- HMRC’s Second Investigation of SKM
- EU background
- Right to credit for input tax
- Liability to a penalty
- Officer’s Liability
- Mitigation
- Case law Authorities
- Denial of credit for input tax - Kittel
- Mobilx
- Limits of the relevance of due diligence
- Reasonable explanations for circumstances of a transaction
- the parties cases
- The Appellants’ case
- consideration of the issues
- Knowledge of the existence and prevalence of fraud in SKM’s trading sector
- Significant trade with a fraudulent defaulter
- No evidence of commercial negotiations
- Lack of contractual documentation
- Issues with invoices
- Lack of commerciality in the way the transactions were structured
- Insufficient due diligence
- Viability of the goods as described by your supplier. For example
- Examples of specific checks carried out by existing businesses
- Looking at the overall picture
- Conclusions
![TC09659 - [2025] UKFTT 01211 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png)