In C4C Investments Ltd v HMRC [2022] UKFTT 367 (TC) (11 October 2022) the FTT denied the taxpayer permission to amend its grounds of appeal holding that the application was late the proposed new grounds had no realistic prospect of success and there was no good reason why the new grounds were not raised at an earlier stage. However the FTT rejected HMRC’s contention that amending the grounds of appeal constituted an abuse of process.
C4C Investments Ltd (C4C) made VAT input tax claims in respect of purchases from DB Recycling Ltd (DBR) but DBR did not account for VAT. The sole director of DBR was also the operations manager of C4C and had responsibility for VAT compliance for both companies. HMRC denied C4C’s input tax claims on the basis that it knew or should have known that it was participating in a...
