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Bertram v HMRC

In Bertram v HMRC [2020] UKFTT 18 (TC) (09 January 2020) the First-tier Tribunal held that HMRC was entitled to raise a ‘best judgement’ assessment against a taxpayer but that he qualified for VAT relief on some of his supplies in relation to the conversion and extension of several residential properties.

Mr Bertram provided goods and services in connection with the conversion of single dwellings into HMOs the subsequent extensions of those HMOs and in some cases conversion of the extensions into new single dwellings (if planning permission could be obtained whilst the extensions were being carried out). He had reclaimed significant amounts of VAT on the costs of these goods and services and apparently took the view that all of his supplies were reduced-rated either as ‘qualifying conversions’ or as ‘residential renovations’ (under VATA 1994 Sch 7A Groups 6 and 7).

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