BOLLINWAY PROPERTIES LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2023] UKUT 00295 (TCC)
Upper Tribunal Tax and Chancery decision of MR JUSTICE RICHARD SMITH JUDGE VINESH MANDALIA on 12 December 2023
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VAT – REPAYMENT SUPPLEMENT – s.79 VATA 1994 – Purchase of properties - whether the inquiry by HMRC requesting a full set of backup documents requires more than sales invoices and purchase document – Yes – Whether it is reasonable to request underlying documents regarding the ‘chargeable event’, including TR1s – Yes. HMRC inquiries conducted within the relevant period – regulation 198 and 199 VAT Regulations 1995 – Appeal dismissed.