In BPF Tanks v HMRC [2019] UKFTT 621 (11 October 2019) the FTT found that HMRC had been reasonable in issuing a notice to provide security.
BPF appealed against a notice to provide security to HMRC in the sum of £110 930.47 (VATA 1994 Sch 11 para 4(2)(a)) and the FTT observed that its jurisdiction was only to assess whether it had been reasonable for HMRC to consider that it was requisite for BPF to provide security. It noted that in doing so it would not take into account events which had happened subsequently to the date of the decision to require security. The original decision to require security had been made on 31 October 2018 and affirmed by a review decision of 8 April 2019. The FTT therefore focused upon the events at the time of the original decision (31 October 2018) but updated with the...
