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All Answers Ltd v HMRC

In All Answers Ltd v HMRC [2020] UKUT 236 (TCC) (30 July 2020) the Upper Tribunal dismissed the taxpayer’s appeal and held that the appellant was supplying essay writing services to customers as principal rather than acting as agent of the third-party essay writers.

All Answers was a company which operated an internet-based business through which customers could in return for payment order academic work (essays dissertations etc.) which were written by third-party writers (who tended to be teachers lecturers or PhD students and who were not employed by All Answers). All Answers would share the fee paid by the customer with the writer (typically retaining about two thirds of the fee for itself). 

The question at the heart of the appeal was whether All Answers was acting as principal and was hence required to account for VAT on the full value of the...

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