UT (Tax & Chancery) UT/2023/00099 - [2025] UKUT 00013 (TCC)

On 7 January 2019, HMRC Officer Mills wrote to the Appellant as follows:

“… Although I have requested information regarding your records, as yet I hold insufficient information to evidence the input tax deducted or payments made against those purchases.

…

At this stage I do not hold the basic records for FS Commercial since commencement. The bank statements provided only related to the one period and do not represent the full bank statements for the business. I will require the full business records and bank statements since commencement. With regard to those statements, although payment is shown as made to Verity, this cannot represent the actual evidence of payment. Verity you have clarified is a number of companies. A single payment therefore cannot represent payment to the individual companies that make up Verity.

…

Can I also repeat my request for a full account listing for Verity showing payments made since commencement of the business? I will also require a detailed makeup of the subsidiary companies that make up each Verity transaction and supporting invoices…

…

At present in the absence of records to substantiate the input tax claimed I will have to disallow all input tax claimed since the commencement of the business

…

If you would like to comment or give me any more information, please contact me by 29 January 2019 …If I do not hear from you by then, I will take this to mean that you agree with my calculations. I will then make assessments of the amount due and send you notice of those assessments…”