TC09666 - [2025] UKFTT 01253 (TC)

It is worth setting out in brief the principal transactions entered into by the Appellant and other parties which relate to the purchase by the Appellant of the Property. This summary is not intended to be complete but serves as background to the issues in this appeal.

The Appellant was incorporated in April 2022 and originally owned by ABC Commercial Ltd which in turn was owned indirectly by two individuals, a Barry Glass and Avi Ratzersdorfer.

On 3 August 2022, solicitors Bude Nathan Iwanier Solicitors (BNI), acting for Jacob and Rivka Dreyfuss transferred £248,000 to Fladgates, appointed to act as the Appellant’s solicitors in the transaction.

On 5 August 2022, the Appellant entered into a contract to purchase the Property from an unconnected company, Marble Acquisitions Limited, for a price, according to the purchase contract, of £2.25m. Fladgates paid the £225,000 deposit to the seller’s solicitors Birketts LLP.

On 10 August 2022 Jacob Dreyfuss became the Appellant’s sole director.

On 6 October 2022 BHNV Development Ltd invoiced the Appellant £230,000 plus £46,000 VAT.

On 7 October 2022 the purchase of the Property was completed.

On 26 October 2022 Colridge Ltd invoiced the Appellant for £24,800 plus £4,960 of VAT.

The purchase price was paid by Eurocent Group Ltd (a company owned by Mr and Mrs Dreyfuss) to BNI. It also paid £276,000 to Fladgates which was used to pay Fladgate’s invoice and the (original) BHNV Invoice.