TC09659 - [2025] UKFTT 01211 (TC)

Officer Borland is a Higher Officer of HMRC and has been involved with the HMRC MTIC team in Cardiff since March 2012. He gave evidence as to his investigations of BTL starting on or around 15 July 2021.

We found Officer Borland to be a credible and reliable witness and accepted his evidence as to matters of fact as set out in our findings of fact.

One point of curiosity in Officer Borland’s evidence is why HMRC did not start an investigation into BTL until 15 July 2021 in spite of having evidence on 7 April 2021 that BTL was trading significant quantities of metal. Officer Borland could not explain why HMRC had not investigated BTL earlier. We refer to this point later.