- In 2016, H Ripley & Co Limited sold scrap metal to Recylink International, treating it as zero-rated supplies.
- HMRC assessed HR for VAT in 2017, claiming insufficient evidence of removal to Belgium.
- HR’s documents included sale invoices, bank statements, weighbridge tickets, consignment notes, emails, and messages.
- P&O boarding cards were obtained over 18 months after transactions.
- The First-tier Tribunal refused HR’s appeal against HMRC’s assessment.
- The Upper Tribunal upheld the FTT’s decision, agreeing evidence was insufficient per VAT Notice 725.
- The UT found no single document proved removal, and combined documents were deficient.
- Evidence obtained after the three-month limit, like boarding cards, was excluded.
- HR did not meet zero-rating conditions, and the UT dismissed HR’s appeal.
Source: taxscape.deloitte.com
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
