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The BHNV Invoice
The BHNV Invoice
On 6 October 2022 BHNV Development Ltd invoiced the Appellant £230,000 plus £46,000 VAT. As described above the Appellant obtained a replacement invoice at the time of the internal review and that invoice is the subject of this appeal.
This invoice purports to be in respect of the provision of services to the Appellant relating to the purchase of the Property. The body of the invoice provided as follows:
Qty | Description | Unit Price | Line Total |
1 | Sale of Cornwall Place, Buckingham • Agency fee for the sourcing of the purchase of Cornwall Place: £90,000. • Consultancy fee for managing the sales process, including all legal work: £60,000. • Commission for identifying and advising on the successful change of use for unit 12a of Cornwall Place: £40,000. • Commission for researching and identifying opportunities to increase the commercial rents for the retail units in Cornwall Place: £40,000 | 1 | £230,000 |
- Heading
- Introduction
- The facts
- Background
- The purchase of the Property
- HMRC’s compliance check and decision making
- Validity of invoices and HMRC’s discretion
- The issues in this appeal
- HMRC’s wider input tax argument
- Validity of invoices and alternative evidence arguments
- The BHNV Invoice
- Validity of the BHNV invoice
- Alternative evidence for the BHNV Invoice
- The Colridge Invoice
- Validity of the Colridge Invoice
- Alternative evidence for the Colridge Invoice
- Conclusions