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Tribunal Upholds Timeliness of HMRC VAT Assessments Against Jeneruhl Trade Ltd Under Kittel Principle

  • The case addressed whether HMRC’s VAT assessments for Jeneruhl Trade Ltd were issued within the statutory one-year time limit.
  • HMRC denied £915,621 in input tax, alleging Jeneruhl’s transactions were linked to VAT fraud and that the company knew or should have known (Kittel principle).
  • The Tribunal found the assessments were timely, as HMRC received key evidence within the year before assessment, including trading pattern information and public red flags about suppliers.
  • The Tribunal rejected Jeneruhl’s claim that HMRC acted irrationally, finding the officer’s actions reasonable and proactive.

Source: bailii.org

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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