Nottingham Forest VAT Assessment Time Limits: Upper Tribunal Burden of Proof Ruling

• HMRC must issue a VAT assessment within two years of the end of the relevant VAT period or within a year of having the necessary facts
• Nottingham Forest Football Club Limited challenged an assessment for underpayment of £345,561 on the August 2015 VAT return
• The Upper Tribunal ruled that the burden of proof was on the club to show when HMRC had the evidence to raise an assessment
• The Upper Tribunal also decided that the First-tier Tribunal had not followed the tests about the one-year rule set out in Pegasus Birds
• The club’s appeal was dismissed by the Upper Tribunal.

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.

---

---