UT/2024/000069 - [2025] UKUT 00236 (TCC)

Case Number: UT/2024/000069

UT/2024/000082

Rolls Building, London, EC4

Value added tax and national insurance contributions – power to de-register a company for VAT purposes pursuant to CJEU decision in Ablessiowhere there was a VAT fraud – whether requirement that the directors of company must have known, or should have known, of the fraud – no – whether the pleading by HMRC about the fraud was sufficient – yes

Judgment date: 17 July 2025

Before

MR JUSTICE RAJAH

JUDGE ANDREW SCOTT

Between

(1) ELPHYSIC LIMITED

(2) PHYARREIDON LIMITED

(3) ROSSCANA LIMITED

(4) ZRAYTUMBIAX LIMITED

Appellants/ Respondents

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents/ Appellants

Representation:

For the Appellants/ Respondents: Mr Margolin KC and Mr MacWhannell of, and Mr Bedenham KC of counsel instructed by, Joseph Hage Aaronson LLP

For the Respondents/ Appellants: Mr Puzey and Mr Millington, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs

DECISION