- H Ripley & Co Limited sold scrap metal to Recylink International in 2016, treating it as zero-rated supplies.
- HMRC assessed VAT on HR in 2017, claiming insufficient evidence of removal to Belgium.
- HR provided various documents as evidence, including sale invoices and international consignment notes.
- P&O boarding cards were obtained over 18 months after transactions.
- The First-tier Tribunal rejected HR’s appeal, and the Upper Tribunal upheld this decision.
- The issue was whether HR had sufficient evidence of removal, not whether the goods were actually removed.
- The UT agreed that the documents did not collectively prove removal from the UK.
- Evidence obtained after the three-month limit, like P&O boarding cards, was excluded.
- HR did not meet the conditions for zero-rating, and the appeal was dismissed.
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.
