Tribunal Rules Separate Supplies in United Carpets Case, Rejects Legitimate Expectation Claim Against HMRC

• The FTT ruled in favor of United Carpets, determining there were separate supplies of goods and services, not a single composite supply.
• Three distinct agreements were identified: between UC and the customer, UC and the fitters, and the fitters and the customer.
• Independent fitters maintained control over their operations and were paid directly by customers.
• UC’s public law argument on legitimate expectation was rejected as HMRC’s communications were not clear or unambiguous.
• The case highlights the need for thorough factual analysis in litigation, which HMRC failed to do, leading to UC’s successful appeal.

Source: rpclegal.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.

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