Poor quality of HMRC argument

Les Howard
VAT Consultant
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In a short decision, the First Tier Tribunal reviewed a number of contracts in relation to the supply of an interest in land, to determine whether the underlying supply was taxable or exempt. The Tribunal held that the supply, being a supply of services (an equitable interest), not goods (a freehold interest), was taxable.

As a footnote, there was some criticism of HMRC; “there was some confusion in the arguments put forward …. some of the arguments …  were hopeless.”

The Tribunal rejected the taxpayer’s argument that HMRC should be barred from the Appeal as they had consistently failed to explain the legal basis of their assessment. The Tribunal held that HMRC’s Statement of Case did provide such basis.


About Les Howard


Hi, I am a VAT Consultant, working mainly with charities. I am based in Cambridgeshire

I have over 20 years experience in VAT, and am currently also a part-time member of the Tax Tribunals.


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